United States     Solid Waste and     EPA530-R-99-037
Environmental Protection  Emergency Response    NTIS: PB99-155 962
Agency	(5305W)	April 1998	
Human Health and
Environmental Damages
from Mining and Mineral
Processing Wastes;
Technical Background
Document Supporting the
Final Rule Applying Phase
IV Land Disposal
Restrictions to Newly
Identified  Mineral
Processing Wastes
     Printed on paper that contains at least 30 percent postconsumer fiber

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       This technical background document, Human Health and Environmental Damages from
Mining and Mineral Processing Wastes, was submitted for public review to EPA's RCRA Docket
# F-95-PH4A-FFFFF. It  provides information to support the January 25, 1996 Supplemental
Proposed Rule, Land Disposal Restrictions—Supplemental Proposal to Phase IV: Clarification of
Bevill  Exclusion for Mining  Wastes,  Changes to the Definition of Solid Waste for Mineral
Processing Wastes, Treatment Standards for Characteristic Mineral Processing Wastes,  and
Associated Issues (61 FR 2338).  The Agency has received comments from the  public on this
document and has listed these comments and Agency responses in this document. The Agency
finalizes this document as of April 1998 and submits it to RCRA Docket # F-98-2P4F-FFFFF to
provide supplementary information and support for the April 1998 Final Rule, Land Disposal
Restrictions Phase IV: Final Rule PromulgatingTreatment Standards for Metal Wastes and Mineral
Processing Wastes; Mineral ProcessingSecondary Materials and Bevill Exclusion Issues; Treatment
Standards for Hazardous Soils, and Exclusion of Recycled Wood Preserving Waste-waters.

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 50272-101
 REPORT DOCUMENTATION  11. Report No.
 12.
13. Recipient's Accession No.
PAGE | |
| EPA530-R-99-037 |
1 1
4. Title and Subtitle
Human Health and Environmental Damages from Mining and Mineral Processing Wastes; Technical Background
Document Supporting the Final Rule Applying Phase IV Land Disposal Restrictions to Newly Identified Mineral
Processing Wastes
7. Authors)
9. Performing Organization Name and Address
US. EPA
OFFICE OF SOLID WASTE
401 M STREET, SW
WASHINGTON, DC 20460
12. Sponsoring Organization Name and Address
1
| PB99-155962
I
1 5. Report Date
I April 1998
\ 6.
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1 8. Performing Organization Rcpt No.
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1 10. Project/Taskwork Unit No.
1
|11. Contract © or Grant (G) No.
|0
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1(0)
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1 13. Type of Report & Period Covered
1
1 Response to Public Comment
|14.
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1
 15. Supplementary Notes
                      PROTECTED UNDER INTERNATIONAL COPYRIGHT
                      ALL RIGHTS RESERVED,
                      NATIONAL TECHNICAL INFORMATION SERVICE
                      U.S. DEPARTMENT OF COMMERCE
 16. Abstract (Limit: 200 words)


 Illustrates the human health and environmental damages caused by management of wastes from mining and mineral processing, particularly
 damages caused by placing them in land-based units. Presents the process EPA used to develop this document. Summarizes the scope and
 variety of the damage cases presented. Discusses the mineral commodity sectors, geographical diversity, waste types, waste management
 practices, and damages covered by the cases. Provides specific illustrative damage cases. Concludes that these examples provide convincing
 evidence that wastes from mining and mineral processing have caused substantial human health and environmental damages.
 17. Document Analysis  a. Descriptors
   b. Identifiers/Open-Ended Terms
   c. COSATI Field Group
 18. Availability Statement


  RELEASE UNLIMITED
| 19. Security Class (Tills Report) | 21. No. of Pages
| UNCLASSIFIED           |
I                        I
| 20. Security Class (This Page)   | 22. Price
| UNCLASSIFIED           |
(SeeANSI-Z39.18)
                               OPTIONAL FORM 272 (4-77)
                               (Formerly NTIS-35)

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Memo: from Van E. Housman to RCRA Docket discussing "Natural Resource Damages from Mining
       Operations"

Document: "Releases from Phosphogypsum Storage Piles"

Also see:
       Guerrero, Peter F., USGAO.  "Superfund: Number and Value of Natural Resource Damage
       Claims." Testimony Before the Subcommittee on the Water Resources and Environment,
       Committee on Transportation and Infrastructure, House of Representatives. July 11, 1995.
       GAO Report Number: T-RCED-95-246

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                                 TABLE OF CONTENTS


                                                                                           Page

CHAPTER 1:  OVERVIEW	•	  1

Purpose of the Background Document	  1

Process for Developing the Background Document	  1

Summary of Damage Cases 	  4

Conclusion	  8

CHAPTER2:  ILLUSTRATIVE DAMAGE CASES	  9

          ARIZONA

Ray Mines Complex: UST Leak, PCB and Acid Spills,
                and Wastewater Transfer	  13

          CALIFORNIA

American Girl Mine:
                Two of Three Releases Were Contained  	  15

Carson Hill Gold Mine:
                Cyanide Solution Spills Into Reservoir  	  17

Grey Eagle Mine:
                Faulty Dam Plagues Operation	  19

Iron Mountain Mine: Uncontrolled Release
                Kills20£000 Salmon	 21

Jamestown Mine: Plagued by Numerous Spills	 23

Mount Diablo Mine:  Mercury From Mine Found in Local
                Streams, Park	 25

Mountain Pass Mine and Mill:
                Lanthanide Mine Contaminating Ground Water	• • • • 27

Pine Creek:  Tungsten Mill
                Leaks Pollutants into Nearby Stream	 29

U.S. Borax Mine:
                Polluting Ground Water	 31

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           COLORADO

ASARCO Globe:
                 Metals Polluted Ground Water and Soil
Clear Creek: Old Mine Waste Tunnels and
                 Tailings Erosion Cause Contamination  	  35

Climax Mine:
                 Molybdenum Mine Tailings Blown Off-Site	  37

Denver Radium:
                 Gold and Silver Mining Wastes Heavily Contaminate Soil	  39

Idarado Mine: Millsite Areas Used for
                 Hazardous Waste Disposal	"  41

Lincoln Park Site:
                 Ground Water Injurious to Cattle	  43

Rubie Heap Leach: Releases of Cyanide
                 from Heap Leaching at Gold Mine	  45

Smeltertown: Bottled Water Needed
                 to Replace Contaminated Well Water 	  47

Smuggler Mountain:
                 Old Mine Listed on NPL	 .  49

Urad Mine and Mill:  Tailings Drainage Contaminates Creek	  51

          FLORIDA

Bartow Chemical Plant:
                 Radioisotopes Contaminate Florida Ground Water	  53

East Tampa Chemical Plant Complex:
                 Acidic Discharge Kills Crabs	  55

Plant City Chemical Complex:
                 Ground Water Contaminated at CPI Plant	  57

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           IDAHO

Blackbird Mine:
                  Endangered Salmon Potentially Affected
                  by Poor Water Quality 	  59

Bunker Hill: One of the Largest
                  and Most Complex NPL Sites	  61

Lucky Friday Mine: Tailings Discharge Kills Fish
                  and Aquatic Insects	  63

Microgold II Mine:
                  Mercury Contamination from Gold Mining	  65

Nu-West Plant:
                  Wastewater Spill Flows Four Miles	  67

           ILLINOIS

Illinois Zinc Plant: Heavy Metals Released
                  by Run-off and Leachate	  69

           KANSAS AND OKLAHOMA

Tar Creek:
                  Mine Water Contaminates Drinking Water Source	  71

           LOUISIANA

Allied-Signal Hydrofluoric Acid Plant:
                  Untreated Wastewater Discharged to Mississippi 	 73

Arcadian Phosphoric Acid Plant: Emergency Discharges
                  of Wastewater Released to Mississippi  	 75

Faustina Works Phosphoric Acid Facility:,
                  Low pH Water Released to St. James Bayou	 77

Ormet Aluminum Plant:
                  Red Mud Discharges Cause High pH in Canal	 79

           MICHIGAN

Torch Lake Copper Mines: Tailings Contaminate Fish
                  and Create Public Health Concern 	 81

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           MISSOURI

Doe Run Lead Smelter:
                 Slag Metals Found in Ground Water	 83

Glover Lead Smelter:
                 Contamination in Ground and Surface Water  	 85

Oronogo-Duenweg Mining Belt:
                 Contaminants Spread Over Wide Area	 89

           MONTANA

Anaconda Smelter: Pollution from Copper Processing
                 Wastes Force a Community to Relocate	 91

Basin Creek Mine:
                 Gold Mine Contaminates Local Waters	-. 93

Cable Creek Project:
                 Spring Thaw Causes Overflow Pond Discharges	 95

East Helena Smelter:
                 Elevated Blood-Lead Levels Found Nearby	 97

U.S. Antimony Mine:
                 Mine Tailings Contaminate Creek and Wildlife	 99

           NEVADA

Nevada Moly Project:
                 Mercury Spilled Down Water Well at Molybdenum Mine	  101

Taylor/Ward Project:      ., _
                 TailingpSpill Pollutes Forest Service Lands 	  103
                       -?fi£';.
           NEWJERSEY^

Glen Ridge  and Monte lair/West Orange:
                 Radioactive Waste Pollutes Residential Soils  	  105

           NEW MEXICO

Chino Mine: Wastewater Overflow
                 and Other Practices Pollute Creek	  107

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Tyrone Mine:
                 Tailings Dams Contaminate Ground Water	  109

          NORTH CAROLINA

Aurora Phosphate Plant: Wastewater Overflow Kills	'	  HI

          NORTH DAKOTA

Great Plains Coal Gasification Plant:
                 Gasifier Ash Contaminates Ground Water	  113

          NORTHWEST UNITED STATES

Confidential Site:
                 Drinking Water Contaminated at Phosphate Mine	 .  117

          OHIO

ASARCO Zinc Smelter:
                 Acutely Toxic Releases to Surface Water 	  119

          OREGON

Martin Marietta Reduction Facility:
                 Aluminum Production Facility Placed on NPL 	  121

Teledyne Wah Chang Albany: Ground and Surface Water
                 Contaminated by Metals Manufacturing Wastes	  123

          PENNSYLVANIA

Aliquippa Works:
                 High pH in Ground Water Leachate	  125

Foote Mineral Company:
                 Lithium Detected in Ground Water	  127

Palmerton Zinc:
                 Enormous Waste Pile Pollutes Soil and Creek	  129

          SOUTH CAROLINA

Brewer Gold Mine: Cyanide Release from
                 Gold Mine Affects Biotic Communities	  131

          SOUTH DAKOTA

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Gilt Edge Project:
                Liner Leaks Contaminate Ground Water
Homestake Gold Mine:
                Heavy Rains Force Homestake to Correct Drainage Problems	 135

          TEXAS

El Paso Plant:
                Run-off and Discharge Pollute Rio Grande  	 137.

          UTAH

Kennecott North:  Tailings from 5,700 Acre Pond
                Pollute Ground Water	 139

Kennecott South:  Drinking Water Wells Contaminated
                by Leach Dumps	 141

Monticello Mill:
                Mill Tailings Contaminate Nearby Community	 143

          VIRGINIA

U.S. Titanium:
                Contaminated Titanium Mine Kills Fish  	 145

          WASHINGTON

ASARCO Tacoma Smelter:
                Copper Slag Contributes to Bay Impacts	 147


CHAPTER 3:  REPORT FINDINGS	 149

APPENDIX A: COMMENTS AND RESPONSES ADDRESSING DAMAGE CASES INACCURACIES
                FOR FACILITIES IN THE 1996 HUMAN HEALTH AND ENVIRONMENTAL DAMAGES
                REPORT  	 151
         ATTACHMENTS:


         Document: "Mining Waste Releases and Contaminants for Selected Facilities"

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                               CHAPTER 1.  OVERVIEW
       This chapter describes (1) the purpose of the background document, (2) the process EPA used to
develop the document, (3) the variety of damage cases included, and (4) conclusion. Chapter 2 presents
66 damage cases.  Chapter 3 presents the report findings.

Purpose of the Background Document

       The U.S. EPA Environmental Protection Agency (EPA) developed this background document to
illustrate the human health and environmental damages caused by management of wastes from mining
(i.e., extraction and beneficiation) and mineral processing, particularly damages caused by placement of
mining and mineral processing wastes in land-based units. These damage case illustrations will provide
technical support Phase IV land disposal restrictions to newly identified mineral processing wastes and
make other regulatory changes.

       Although the damage cases in this report do not represent a statistically representative sample of
all mining and mineral processing sites or the damages they have caused, the cases do provide
convincing evidence that wastes from mining and mineral processing have caused significant human
health and environmental damages. Both wastes that are subject to and, under the Bevill Amendment
(RCRA §3001(bX3)(AXI-iii), exempt from regulation as hazardous wastes under Subtitle C of the
Resource Conservation and Recovery Act (RCRA) are responsible for these damages.  These damages
occur across a broad  range of mineral commodity sectors—from alumina to zirconium—and throughout
all regions of the United States, in a wide variety of climatic and geological zones and in both rural and
urban areas.

Process for Developing the Background Document

       In preparing  this background document, EPA sought to support selected aspects of the regulation
by providing readily  available examples of human health and environmental damage caused by wastes
from mining and mineral processing.  EPA relied primarily on the extensive data on damages from the
management of mining and mineral processing wastes that EPA had previously collected and analyzed.
To identify a few additional cases, EPA conducted limited new data gathering that was feasible within
project constraints; In identifying existing and new damage cases to compile, EPA selected cases that
demonstrate that human health and environmental damages occur across a wide range of mineral
commodity sectors and throughout the United States.

       EPA performed three steps to assemble this document:

       (1)    Compiling existing damage case summaries;

       (2)    Reviewing relevant inspection, enforcement, permitting, and other relevant files for
              mining and mineral processing facilities in selected states; and

       (3)    Soliciting the help of EPA Region 10 in drafting new damage cases.

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Each of these steps is discussed in more detail below. While EPA also started a literature review to
identify additional sites, this exercise was not completed, for two reasons. First, the results of initial
searches were largely unsuccessful in identifying new damage cases.  Second, other data gathering
approaches appeared to be more cost-effective. Nevertheless, one damage case was based on a federal
court ruling obtained through the  initial literature review.

       Compiling Existing Damage Cases

       EPA has conducted previous studies identifying human health and environmental damages
caused by mining and mineral processing waste management activities. Four of these documents were
used as the basis for preparing damage cases for this document:

       (1)     Report to Congress on Special Wastes from Mineral Processing, July 1990, U.S.
               Environmental Protection Agency.  This report contains 16 damage cases
               addressing some of the 20 mineral processing wastes  that EPA determined to
               eligible for the Bevill exemption from RCRA Subtitle C. These wastes are in 12
               mineral commodity sectors  and are generated by approximately 91 facilities
               located within 29 states.1

       (2)     Mining Waste Release and Environmental Effects Summaries, Draft, March
               1994, U.S. Environmental Protection Agency. This draft report identified
               damage from mining and mineral processing wastes at 114 mining sites in 9
               states.2  These cases include some damages from mineral processing wastes
               because mining and mineral processing operations are co-located at some
               facilities.

       (3)     Mining Sites on the National Priorities List: NPL Site Summary Report, U.S.
               Environmental Protection Agency, June 21, 1991. These cases cover 48
               seriously contaminated mining and mineral processing sites in 21 states that
               were included on  the National Priorities (NPL) List by 1991.

       (4)     Mining Sites on the NPL, U.S. Environmental Protection Agency, August 1995.  This
               document includes 32 mining and mineral processing sites that were added to the NPL
               between 1991  and 1995.

       This background report includes all  16 damages cases from the 1990 Report to Congress.  To
supplement these Report to Congress cases and expand the mineral commodity sectors and geographic
array of sites covered, EPA selected an additional 24 cases from Mining Waste Release and
Environmental Effects Summaries, 17 cases  from the Mining Sites on the National Priorities List (1991),
and 3 cases from Mining Sites on the NPL (1995).  While only 60 of the 188 damage cases in the four
studies are depicted in this background document, these 60 cases cover a broad range of mineral
   1 Report to Congress on Special Wastes from Mineral Processing, Volume II, page 1-2.

   2 The waste release data from these reports are summarized in Profile of the Metal Mining Industry,
September 1995, Office of Compliance Sector Notebook Project, U.S. Environmental Protection Agency,
pages 37-45.

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commodity sectors and states, as described below. (An additional damage case was based on
enforcement-confidential data sources; five other additional cases were based on information from other
State and Federal Agencies.) All these case descriptions have been condensed and reformatted in a
consistent manner.

        Reviewing State Files

        EPA contacted environmental protection agencies in six states to obtain recent information for
developing new damage cases:

        *      Alabama                     *     Massachusetts
        *      California                    +     New Jersey
        *      Colorado                     *     Pennsylvania

These states were selected for their diversity in mineral processing and mining sectors and their
geographic range. In addition, they were selected to minimize data collection costs by allowing the EPA
contractor to rely on staff already located in or traveling for other reasons to these jurisdictions.

        Based on conversations with state representatives, EPA conducted limited file searches in the
state capitals of Alabama, California, and Colorado. A minimum of 10 mining and/or mineral processing
facilities in each state were identified as targets for the file searches. These facilities were selected to
avoid duplication with facilities covered by any of the documents listed above. These target facilities
were identified essentially in a random manner, without any information concerning the likelihood of
identifying evidence concerning human health or environmental damages.

        These file searches did not provide any useful data for developing damage case summaries in
Alabama and California. In Alabama, evidence of environmental damage or human health impact data
was not identified in the state files reviewed for the target sites. Upon arrival in Sacramento, California,
it was determined that inspection and enforcement documents, such as Notices of Violation,  were not
maintained at the state file room, but were available only at local district environmental protection
offices. Subsequently, EPA contacted three local environmental agencies to seek data to develop
damage case summaries.  Within the available time and resources, however, EPA was unable to visit
these offices or otherwise obtain information concerning any damage cases.

        The Colorado Department of Health provided EPA with a bibliography of readily available files
maintained at their offices in Denver. EPA visited the state offices and compiled three damage cases
based on the available data.

        EPA did not conduct file searches in New Jersey,  Massachusetts, or Pennsylvania for a number
of reasons. In Pennsylvania, environmental and human health information is maintained within the six
State district offices.  Because of the small number of sites in each district and the time required to set  up
and conduct a file search, these files were not examined. New Jersey also was not selected because of
the long lead time required to set up a file  review appointment at the State file room in Trenton. Finally,
a file search was not conducted in Massachusetts because  the State geologist was unable to identify any
mining or mineral processing sites with known environmental or human health damages.

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        Obtaining EPA Region 10 Summaries

        EPA contacted its EPA Region 10 staff who are responsible for overseeing the cleanup of mining
and mineral processing sites in Alaska, Idaho, Oregon, and Washington to solicit their assistance in
developing new damage case summaries. Region 10 staff prepared one damage case and provided
supplemental information for a damage case also based on other sources.

        In summary, EPA completed a limited three-step effort to identify 66 illustrative mining and
mineral processing damage cases in a variety of mineral commodity sectors and states. Thus, these cases
should not be seen as either an exhaustive survey or as a statistically representative sample of damage
cases.

Summary of Damage Cases

        This section describes the scope and variety of the damages presented, in Chapter 2.  Specifically,
it discusses the mineral commodity sectors,  geographic diversity, waste types, waste management
practices, and damages covered by cases.

        Mineral Commodity Sectors

        The damages described in this background document occurred at 66 facilities in the following 23
mineral commodity sectors:

        ^      alumina                     4       aluminum
        *      antimony                    *       boron
        *      cadmium                    *       cerium, lanthanides, and rare earths
        *      coal gas                     4       copper
        f      gold and silver               *       hydrofluoric acid
        *      iron and steel                 *       lead
        *      lithium                      *       mercury
        4      molybdenum                 4       phosphoric acid
        *      tantalum/columbium          *       titanium
        ^      tungsten                     4       uranium
        *      vanadium                    +       zinc
        *      zirconium/hafnium

These sectors encompass most of the major  mining and mineral processing sectors affected by the
proposed rule. These damage cases represent sites in 18 of the 31 sectors potentially affected by the
proposed rule. Moreover, these 18 sectors account for most of the predicted costs that would be imposed
by the proposed rule.  For example, these sectors account for more than 90 percent of the estimated
incremental land disposal restrictions (LDR) treatment costs under Option 2 under the no prior treatment

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baseline.3 These sectors also cover all the major metal mining4 and several non-metal mineral mining
sectors.

        Geographic Diversity

        The 66 damage cases are for facilities located in 26 of the 50 United States. The states included
are scattered across all regions of the nation, as shown in the table below.

                  Exhibit 1. Damage Cases Are Located Throughout the Nation
Region of United States
North East/Mid-Atlantic
South
Midwest/Central
Mountain West
West Coast
States With Damage Cases Presented
New Jersey, North Carolina, Pennsylvania,
Virginia
Florida, Louisiana, South Carolina, Texas
Illinois, Kansas, Michigan, Missouri, North
Dakota, Oklahoma, Ohio, South Dakota
Arizona, Colorado, Idaho, Montana, Nevada,
New Mexico, Utah
California, Oregon, Washington
       These regions and states vary considerably in terms of their climate, from dry desert conditions
to abundant rainfall, in their geology, and in their urban or rural characters.

       Climate. The damage case facilities are located in climates that vary widely, such as the
Taylor/Ward Project in the Nevada desert, which has about 4 inches of precipitation annually, to the Doe
Run site in Missouri's Ozarks, which has an annual mean precipitation of about 46 inches.

       Geology.  The damage case facilities are also located in a wide range of environments. For
example:

       +       The Tar Creek Site on the Kansas/Oklahoma border encompasses several mines
               that open into the Boone formation, a cherty limestone deposit averaging about
               370 feet in thickness. Two dolomite layers lay below the Boone formation, and
               a layer of cherty dolomite with several sandy sequences is under these layers.
               Surface features are characterized by numerous tailings piles consisting
               primarily of limestone and chert.
   - exhibit 4-5, Regulatory Impact Analysis of the Supplemental Proposed Rule Applying Phase IV Land
Disposal Restrictions to Newly Identified Mineral Processing Wastes, December 15, 1995, U.S.
Environmental Protection Agency, Office of Solid Waste, page 4-16.
   4 See, for example, Profile of the Metal Mining Industry, supra footnote 2.

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        +      The Palmerton Zinc Site in Pennsylvania is situated at the confluence of the
               Lehigh River and Aquashicola Creek, just north of the Lehigh water gap.  The
               site lies in a deep valley within the Appalachian Mountains, between Blue
               Mountain and Stony Ridge, which are 1,500 and 900 feet above sea level,
               respectively.

        *      The regional surficial and bedrock geology of in the vicinity of Texasgulf s
               Aurora, North Carolina site comprises a stratigraphy of approximately 150 feet
               of surficial soils overlying several hundred feet of limestone and marine
               sediments.

        +      The Nu-West facility in southeast Idaho is characterized by broad, flat valleys
               with base elevations near 6,000 feet.  It is located at the eastern margin of the
               Blackfoot lava field.  Bedrock beneath the site is basalt overlain by 5 to 25 feet
               of recent sediments.

        Urban versus Rural Surroundings. The sites also vary in their nearby populations and associated
real estate developments.  For example:                                                       -   '

        *      The Smuggler Mountain Site is within the city of Aspen, Colorado, which has a
               year-round population of 4,500.  In many cases, development in the Aspen area
               has taken place directly over waste piles, or waste piles have been moved to the
               side of developed areas and remain as berms or mounds of contaminated soil.
               The site is approximately 90 percent developed as residential housing.

        *      The Glen Ridge,  Montclair/West Orange, and U.S. Radium sites in New Jersey
               cover more than 200 acres of suburban and residential areas.

        *      The Torch Lake,  Michigan area is a former copper mine boom town, which is
               maintained as a wildlife and recreational area. Sparsely populated by year-round
               residents, many people own cottages at or near the lake which they use
               seasonally.

        +      The U.S. Titanium site in Virginia is set in a rural area populated by 200 people.
               Most residences are within a one mile radius of the site. The closest residence is
               2000 feet to the west of the site.

        Waste Types

        The damage cases demonstrate that a wide assortment of extraction, beneficiation, mineral
processing, and non-uniquely associated wastes are responsible for human health and environmental
damages.5 The  wastes responsible for the damages are identified at the start of each damage case.
   5 For a description of potentially hazardous mineral processing wastes streams, see Identification and
Description of Mineral Processing Sectors and Waste Streams, Section IV, Final, April 1998, U.S.
Environmental Protection Agency.  For a description of Bevill exempt mineral processing wastes streams,
see the 1990 Report to Congress, Chapters 3-14.  For a description of mining waste streams, see Report

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        Damages have been caused by exempt as well as non-exempt wastes.  Most of the damage cases,
however, are linked to exempt mining or mineral processing wastes, for several reasons:

        *      One of the major sources for the cases, the 1990 Report to Congress, focused
               exclusively on exempt wastes.

        *      A second major data source, Mining Waste Release and Environmental Effects
               Summaries, focused on mining sites and mining wastes that are generally exempt
               from Subtitle C regulation under the Bevill Amendment.

        *      In addition, where damages are caused by mixtures of exempt and non-exempt
               wastes, the contribution of non-exempt wastes, which are likely to be much
               smaller in volume, may have been difficult to identify or otherwise were not
               identified.

        For further information about the pollutants of concern in wastes from mining and mineral
processing, see materials developed for EPA's storm water program, such as 58 Federal Register 61146,
61223-51, 61269-85 (November 19, 1993). Three of 11 categories of industrial facilities subject to storm
water permitting requirements include mining and mineral processing facilities:

        +      Metal mining (ore mining and dressing) facilities (SIC 10);

        *      Mineral mining and processing facilities (SIC  13);  and

        *      Primary metals facilities (SIC 33).

The Federal Register notice cited above contains fact sheets for each of these three industry categories
which discuss the industrial activities, including waste management practices, and the pollutants of
concern potentially associated with each activity. These fact sheets describe the major activities
representative of many of the facilities in these industries.

        Waste Management Practices

        The cases demonstrate that land-based management practices for mining and mineral processing
wastes are responsible for considerable damages to human health and the environment.  These damages
commonly arise from land placement of wastes in unlined units having minimal engineered release
controls. These units include piles of slags, dusts, refractory bricks, sludges, waste rock/overburden, and
spent ore; surface impoundments containing mill tailings and/or process wastewaters; and heap leaching
solution ponds. In addition, many, if not most of the damage case facilities have caused human health or
environmental damages through leaks or spills, such as releases from lined management units, valves,
and pipes. An attachment to this report, for example, summarizes available data on releases from the
sites described in the Mining Waste Release and Environmental Effects Summaries.  For more
information on common waste management practices used for mining and mineral processing wastes, see
to Congress on Wastes from the Extraction and Beneficiation of Metallic Ores, Phosphate Rock,
Asbestos, Overburden from Uranium Mining, and Oil Shale, 1985, U.S.  Environmental Protection Agency.

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the background document, Identification and Description of Mineral Processing Sectors and Waste
Streams, supra footnote 5, and sources cited therein.

        Human Health and Environmental Damages

        The damage cases illustrate the wide variety of human health and environmental impacts caused
by wastes from mining and mineral processing operations, including groundwater, surface water, and soil
contamination, air deposition, human health damages or risks, and damages to vegetation, wildlife, and
other biota. Most of the cases contain several types of impacts. The wide variety and frequency of
damage is illustrated in the following chart, which is based on the readily information available;
additional impacts may have occurred at the sites.

                                          Exhibit 2.
                            Frequency of Various Types of Impacts
Type of Impacts
Surface water contamination
Ground water contamination
Soil contamination
Human health impacts
Flora and fauna damage
Air deposition or fugitive emissions*
Portion of Damage Cases
70 percent of cases
65 percent
50 percent
35 percent
25 percent
20 percent
- Excludes releases associated with air pollution control requirements or devices
Mineral Processing Specific Environmental Damages

       In selecting damage cases to include in this document, EPA made no special efforts to include
damages specifically caused by mineral processing wastes. Thus, the limited number of damage cases
directly linked to mineral processing wastes cannot be taken to indicate the infrequency of such damages.
Indeed, the cases include several examples of substantial human health and environmental damages
caused by non-exempt wastes. See, for example, the damage cases for Ray Mines Complex, Arizona;
Globe Paint, Denver, Colorado; Anaconda Smelter, East Helena Smelter, and U.S. Antimony, Montana;
Palmerton Zinc, Pennsylvania; and U.S. Titanium in Virginia.

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        The Agency received comments indicating that an earlier draft of this report did not include data
which clearly indicates that mineral processing wastes have caused environmental damages. The Agency
does not agree with the commenters' position.  Since 1989 the Agency has placed considerable amounts
of data which detail the scope of environmental damages caused by mineral processing wastes.  In
response to comments, the Agency has reevaluated each case involving mineral processing wastes and
presents below summary of the 24 mineral processing specific damage cases in this report. Each of
these 24 cases involve damages caused by the improper management of mineral processing wastes.
More complete descriptions of the nature of environmental damages are found in Chapter 2. It should
be noted, that in many cases the companies involved did take actions to remediate environmental releases
and damages.  Nevertheless, these cases provide important insight into the types and range of
environmental damages caused by mineral processing wastes. Based on this reevaluation of data, the
Agency continues to conclude that the improper management of mineral processing wastes has led to
environmental damages.

        The Asarco Ray case dealt with groundwater contamination caused by the placement of mineral
processing waste waters in 17 surface impoundments. At US Borax there were releases to ground water
from impoundments.  Groundwater was found to have 4,000 mg/1 arsenic.  These ponds were ultimately
removed from service by the company. At Asarco-Glover mineral processing waste piles and
sedimentation ponds lead to ground water contamination. Ground water was found contaminated with
lead and zinc.  The Arcadian phosphoric acid facility contaminated groundwater from process waste
water ponds placed on phosphogypsum stacks. At the Nu-West facility ground water was contaminated
from unlined ponds. Groundwater was contaminated with cadmium and fluoride. The Anaconda NPL
site has  arsenic soil and ground water contamination caused by flue dust piles at the site.  Although this
flue dust was not being recycled at the damage site,  the same dust is recycled elsewhere in the industry.
The Agency believes this incident illustrates the potential for harm in placing mineral processing wastes
in open  piles. The ASARCO East Helena facility stored process waste waters in ponds before reuse. The
ponds seeped hazardous constituents into groundwater.  Ground water was contaminated with arsenic,
cadmium, copper, lead and zinc.  The Great Plains coal gasification facility placed gasifier ash and other
mixed processing wastes in an onsite landfill which  caused ground water contamination.  Ground water
was found to has a pH of 12.7 to 13.7 and arsenic was found at  13.8  mg/1 to 22 mg/1. Great  Plains did
discontinue this practice.

Conclusion

        The 66 damage cases presented in the following chapter of this background document illustrate
the significant human health and environmental damages caused by the management of wastes from
mining and mineral processing, particularly placement in land-based units. Both wastes that are subject
to and, under the Bevill Amendment (RCRA §3001(b)(3)(AXI-"i)),  exempt from  regulation as hazardous
wastes under RCRA Subtitle C have caused these damages. The damages have occurred across the broad
range of mineral sectors, including virtually all the sectors affected by the regulation to apply Phase IV
land disposal restrictions to newly identified mineral processing wastes and make other regulatory
changes. In addition, the damages have occurred throughout all regions of the United States, in a wide
variety of climatic and geological zones and in both rural and urban  areas.

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                CHAPTER 2.  ILLUSTRATIVE DAMAGE CASES
      This chapter presents 66 cases of human health and environmental damages caused by mining
and mineral processing wastes. These damage cases are alphabetically by state and within each state
alphabetically by site name, as shown in Exhibit 3.

                                     Exhibit 3.
      List of Damage Case Summaries from Mining and Mineral Processing Wastes
State
Arizona
California
California
California
California
California
California
California
California
California
Colorado
Colorado
Colorado
Colorado
Colorado
Facility
Ray Mines Complex*
American Girl Mine
Carson Hill Gold Mine
Grey Eagle Mine
Iron Mountain Mine
Jamestown Mine*
Mount Diablo Mine
Mountain Pass Mine and Mill
Pine Creek*
U.S. Borax Mine*
ASARCO Globe*
Clear Creek
Climax Mine*
Denver Radium
Idarado Mine
Sector
Copper
Gold
Gold
Gold and silver
Copper, gold, silver,
and zinc
Gold
Mercury
Lanthanide
Tungsten
Borax/borate
Antimony, cadmium,
copper, gold, lead,
indium, silver,
tellurium, and thallium
Gold
Molybdenum
Gold and silver
Copper, gold, lead,
silver, and zinc
Operating
Status
Active
Active
Active
Active
Inactive
Active
Inactive
Active
Active
Active
Active
Active
Inactive
(standby)
Inactive
Inactive

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                        Exhibit 3. (continued)
List of Damage Case Summaries from Mining and Mineral Processing Wastes
State
Colorado
Colorado
Colorado
Colorado
Colorado
Florida
Florida
Florida
Idaho
Idaho
Idaho

Idaho
Idaho
Illinois-
Kansas and
Oklahoma
Louisiana
Louisiana
Louisiana
Louisiana
"••"hioan
Facility
Lincoln Park
Rubie Heap Leach
Smeltertown
Smuggler Mountain
Urad Mine and Mill*
Bartow Chemical Plant
East Tampa Chemical Plant Complex
Plant City Chemical Complex
Blackbird Mine
Bunker Hill
Lucky Friday Mine

Microgold JJ Mine
Nu-West Plant
Illinois Zinc Plant
Tar Creek
Allied-Signal Hydrofluoric Acid Plant
Arcadian Phosphoric Acid Plant
Faustina Works Phosphoric Acid Facility
Ormet Aluminum Plant
Torch Lake Copper Mines
Sector
Uranium, thorium, and
vanadium
Gold
Lead, copper, silver,
gold
Silver, lead, and zinc
Molybdenum
Phosphoric acid
Phosphoric acid
Phosphoric acid
Copper and cobalt
Cadmium, lead, silver,
zinc, phosphates, and
sulfuric acid
Gold, silver, lead, and
zinc

Gold
Phosphoric acid
Zinc
Lead and zinc
Hydrofluoric acid
Phosphoric acid
Phosphoric acid
Alumina (bauxite)
Copper
Operating
Status
Inactive
Active
Active
Inactive
Inactive
Active
Active
Active
Inactive
Inactive
Active

Inactive
Active
Inactive
Inactive
Active
Active
Active
Active
Inactive

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                        Exhibit 3. (continued)
List of Damage Case Summaries from Mining and Mineral Processing Wastes
State
Missouri
Missouri
Missouri
Montana
Montana
Montana
Montana
Montana
Nevada
Nevada
New Jersey
New Mexico
New Mexico
North Carolina
North Dakota
Northwest
United States
Ohio
Oregon
Oregon
Pennsylvania
Facility
Doe Run Lead Smelter
Glover Lead Smelter*
Oronogo-Duenweg Mining Belt
Anaconda Smelter
Basin Creek Mine
Cable Creek Project
East Helena Smelter*
U.S. Antimony Mine
Nevada Moly Project*
Taylor/Ward Project
Glen Ridge and Montclair/West Orange
Chino Mine*
Tyrone Mine*
Aurora Phosphate Plant
Great Plains Coal Gasification Plant
Confidential Site
ASARCO Zinc Smelter*
Martin Marietta Reduction Facility
Teledyne Wah Chang Albany
Aliquippa Works
Sector
Lead
Lead
Lead and zinc
,' Copper
Gold
Gold and other
precious metals
Lead and zinc
Antimony
Copper and
molybdenum
Lead and silver
Uranium, thorium, and
vanadium
Copper
Copper
Phosphoric acid
Coal gasification
Phosphate
Zinc
Aluminum
Hafnium, niobium,
tantalum, vanadium,
zirconium
Iron/steel
Operating
Status
Active
Active
Inactive
Inactive
Active
Active
Active
Active
Inactive
Active
Inactive
Active
Active .
Active
Active
Active
Inactive
Inactive
Active
Inactive

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                                 Exhibit 3. (continued)
       List of Damage Case Summaries from Mining and Mineral Processing Wastes
State
Pennsylvania
Pennsylvania
South Carolina
South Dakota
South Dakota
Texas
Utah
Utah
Utah
Virginia
Washington
Facility
Foote Mineral Company*
Palmerton Zinc
Brewer Gold Mine
Gilt Edge Project
Homestake Gold Mine
El Paso Plant*
Kennecott North*
Kennecott South*
Monticello Mill
U.S. Titanium
ASARCO Tacoma Smelter*
Sector
Lithium
Lead and zinc
Gold
Gold
Gold and silver
Copper, lead, and zinc
Copper
Copper
Uranium and
vanadium.
Titanium
Copper
Operating
Status
Inactive
Inactive
Active
Active
Active
Active
Active
Active
Inactive
Inactive
Inactive
Note: The "Operating Status" listed for each of the facilities in Exhibit 3 is taken from either (1)
the summary write-ups in this chapter, (2) Randol International Ltd's. Mining Directory 1994/95,
U.S.  Mine and Mining Companies, Golden, CO 1994, or (3) EPA's Identification and Description
of Mineral Processing Sectors and Waste Streams, Technical Background Document,
Appendices F and G, December 15,  1995. The accuracy of a facility's reported operating
status is limited to the files reviewed.  "*" Denotes cases revised to include information
submitted in industry comments (Appendix A summarizes these comments).

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Arizona
      Ray Mines Complex:  UST Leak, PCB and Acid Spills,
                         and Wastewater Transfer
   Sector: Copper

   Facility: Ray Mines Complex (Hayden Plant), ASARCO, Gila County, AZ

   Facility Overview: A copper smelting facility. No mining or beneficiation took place on-
   site.
Waste Stream(s): Electric slag cleaning vessel (ESCV) slag, acid plant blowdown, brine
concentrator blowdown, and other process wastewater.

Waste Management Practices: The facility had 17 surface impoundments, including a   -  *
rubberized-asphalt lined wastewater treatment pond. ESCV slag containing iron, silica, and
other constituents was placed in piles on-site. Acid plant blowdown containing calcium sulfate
sludge was neutralized with lime and mixed with silica to produce a flux suitable for use in the
flash smelter.  According to Asarco, acid plant blowdown was neutralized in the wastewater
treatment plant and the solids were sent to the lined impoundment. Brine concentrator
blowdown was the only process wastewater discharged to the lined wastewater treatment pond,
and according to Asarco, ceased in 1991.  Other wastewater was generally handled by the
wastewater treatment plant.  Until 1990, the lined wastewater treatment pond received acid
plant blowdown to settle out the calcium sulfate sludge. Sludge continued to be excavated from
the water treatment pond to recover trace amounts of copper.  Other process wastewater was
discharged to a central lagoon, separate from the wastewater treatment plant pond. Other
waste management units at the Hayden Plant included a solid waste landfill, a drum storage
area, and an asbestos landfill.

      In December 1990 and January 1991,  large quantities of wastewater were pumped from
the lined wastewater treatment pond into an unlined pond to prevent overflowing due to large
amounts of rainfall. ASARCO reported that the transferred water was of the quality normally
received by the unlined pond.

Type of Impact/Media Affected:  Releases of contaminants to the environment had occurred
at the  facility through  leaks from underground storage tanks (USTs) containing gasoline and
diesel fuel, a spill of polychlorinated biphenyl,  and a spill of 20  tons of sulfuric acid. The leaking
USTs  contaminated soils with aromatic constituents (benzene, toluene, and xylene (BTX)) at
levels exceeding the Arizona Health Based Guidelines.  The PCB spilt contaminated an area
comprised of soil, a concrete pad, the perimeter fence, railroad tracks,  and a vehicle adjacent to
the concrete pad. Employees spread a  clay absorbent to dry up the spill, and all contaminated
material was placed in drums and isolated with the contaminated vehicle.

Regulatory Action/Response: The Hayden  Plant was issued a National Pollution Discharge
Elimination System (NPDES) permit effective  January 30, 1983 through November 11, 1987.

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                                                                         Arizona
The permit allowed ASARCO to discharge cooling tower blowdown to the Gila River. In
October 1984, the Arizona Department of Health Services informed ASARCO of deficiencies in
monitoring and reporting of its Hayden Plant wastewater treatment system.  EPA Region 9
issued a Finding of Violation and Order to ASARCO in May 1985 for a low pH condition in the
acid plant effluent discharged to the Gila River.  The Order required immediate remediation,
monitoring, and future NPDES compliance. After a period of satisfactory compliance, EPA
terminated the Order. No information was provided in the reference on any regulatory action
resulting from the LIST leak or the chemical spills mentioned above. Asarco reports that the
underground storage tanks containing gasoline and diesel fuel have been removed and
replaced with above-ground tanks. Asarco also states that all PCB and sulfuric acid spills, and
gasoline contamination have been completely remediated, and the diesel fuel remediation is
almost finished.

Comments were received on this damage summary.  See Appendix A for comment fisting and
Agency response.

References: U.S. EPA. Draft. Mining Waste Releases and Environmental Effects  Summary
for the State  of Arizona.  March 1994.

ASARCO.  Comments to Phase IV Proposed Rule on  Land Disposal Restriction to Mineral
Processing Wastes. 1996.

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California
                            American Girl  Mine:
               Two of Three Releases Were Contained
   Sector: Gold

   Facility: American Girl Mine, American Girl Mining Corporation, Imperial County, CA

   Facility Overview: This facility consisted of a surface mine and mill and at least two
   heap leach pads. The main processes were cyanide heap leaching and processing.
W
a
st
e
St
re
a
m
(s
Mine water, waste rock, spent ore, and spent leaching solution.
Waste Management Practices: A weak solution of sodium cyanide was distributed across the
top of the heap of crushed gold ore.  The solution was collected and treated to remove the gold
then recycled back to the heap. The leaching ponds were lined and utilized leak detection
systems.

Type of Impact/Media Affected: During the week of December 6, 1987, 1,700 gallons of
pregnant solution leaked into the pregnant pond detection sump and were contained by the
underliner. Three leaks were located and repaired.

      On February 29, 1988, the facility discovered a leak at a new leach pad. An estimated
4,320 to 8,640 gallons of solution containing 4.68 to 9.36 pounds of cyanide were released.
The spill was isolated immediately and the leak repaired. Clay liners were assumed to have
contained the leak.

      On August 4, 1989, a heap pile return hose  became disconnected. Crushed ore
became saturated and weakened, causing a slope failure releasing ore and pregnant solution
outside the containment berm  and liner. The material was returned to the pad, while some
areas were treated with dry hypochlorite to destroy  any cyanide. Laboratory tests of soil
samples by a California Registered Environmental Assessor led to the conclusion that all of the
contaminated soils were removed.

Regulatory Action/Response: The operator provided notice to the state when the releases
described above occurred. No information was gathered on any enforcement actions taken as
a result of any of the releases.

No comments were received on this damage summary.

References: U.S. EPA.  Draft. Mining Waste  Releases and Environmental Effects Summaries
for the State of California. March 1994.

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California

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 California
                           Carson Hill Gold Mine:
                 Cyanide  Solution Spills  Into  Reservoir
   Sector:  Gold

   Facility: Carson Hill Gold Mine, Western Mining Corporation, Calaveras County, CA

   Facility Overview: This facility conducted open pit gold mining and beneficiation.  The
   site included three heap leach piles, pregnant and barren ponds, and a processing plant
   for carbon adsorption.
Waste Stream(s):  Waste rock, mine water, spent ore, and spent leaching solution.

Waste Management Practices: The normal flow of operations at the site was as follows:  -  .

•      Mined ore was crushed and transferred to the leach heaps.

•      Alkaline cyanide solution from the barren pond was applied to the ore heaps, dissolving
       gold in the ore as it percolated down through the heap.

       •      Leachate was piped from the periphery of the pads for transfer to the
             pregnant ponds.

             Pregnant solution from the pregnant ponds was pumped to the plant for
             gold recovery.

       •      Finally, spent solution was returned to the barren pond, completing the
             circuit.

       Prior to 1988, two leach units (Unit 1 and Unit 2) were in operation. A third unit was
constructed m 1988, and Unit 2 was extended in 1989.  Unit 1 received no ore after late 1989
and began detoxification for final closure with fresh water rinsing and recirculation.

Type of Impact/Media Affected:  On May 16, 1989, 91,450 gallons of pregnant solution were
accidentally discharged from Unit 3 into the nearby Melones Reservoir.  Soils, along the
drainage between the facility and the  reservoir were contaminated.  The spill was caused by a
loose pipe coupling in the leachate containment system above a spillway outlet.  Because the
spillway terminated outside the fluid management system, the release traveled beyond facility
• boundaries into the reservoir. Sampling of reservoir water six hours after the spill detected free
cyanide levels below 0.1  mg/L.  Further sampling eight days after the spill yielded no trace of
cyanide or other metals above background levels.

Regulatory Action/Response: After assessing the extent of the release, Carson Hill staff
notified the appropriate federal and state agencies, including the California Regional Water

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                                                                     California
Quality Control Board, the California Department of Fish and Game, the Bureau of Land
Management, and EPA's National Response Center. No information was gathered on any
regulatory actions taken as a result of the 1989 spill.

No comments were received on this damage summary.

References:  U.S. EPA.  Draft.  Mining Waste Releases and Environmental Effects Summaries
for the State of California. March 1994.

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California
                               Grey Eagle Mine:
                      Faulty Dam Plagues Operation
   Sectors:  Gold and silver

   Facility: Grey Eagle Mine, Noranda, Siskiyou County, CA

   Facility Overview: This facility, which operated from 1982 to 1986, excavated, crushed
   and extracted metals from ore using the carbon-in-pulp leach method. Beneficiation
   entailed adding water, flocculants, lime, sodium hydroxide, activated carbon, and sodiun
   cyanide to the ore.
Waste Stream(s):  Tailings.

Waste Management Practices: Tailings were deposited as a slurry in the tailings
impoundment in the dammed canyon of the South Fork of Luther Gulch Creek.  The dam \
designed to prevent pollutant transport from the containment reservoir. Creek flows were
diverted around the reservoir, which contained approximately 827,000 tons of tailings.

Type of Impact/Media Affected: In early February 1983, shortly after commencing
operations, site inspections revealed that the toe of the impoundment dam was leaking. T
drainage pipes were discharging solution with high amounts of cyanide and acidic pH leve
flowing at rate of 15 to 30 gallons per minute. By April 1983, a permanent pumping syster
seepage treatment infrastructure were operating at the toe of the dam. Initially, pumps
redirected the seepage back into the impoundment reservoir.  Later, pumpback was limite
weekends only, since the facility planned to cap the reservoir upon closure and install facii
to treat all seepage. The reservoir was capped in 1987.  A seepage treatment system wa
built; it consisted of a slurry wall for containment, a French drain system for collection, a
treatment plant, and a leachfield for waste disposal.

       The site experienced several accidental discharges over its four-year operating lift
most, though not all, spiUs being related to the facilities constructed to treat and dispose c
toe-of-dam seepage. Unrelated spills included a line rupture on January 4, 1983, resultin
spill of on-site, recycled tailings dam water containing high levels of cyanide. Between  1,'
and 1,500 gallons of solution were released; the discharge, however, was captured in a
sedimentation pond and treated. On June 8, 1986, a surge storage tank overflowed at 3!
gallons per minute. The discharge was detected the following morning and pumps at the
collection well started and the discharge ceased. Approximately 19,100 gallons were
discharged directly into Luther Gulch Creek. Water sampling that day detected cyanide i
copper levels exceeding both state and federal standards 1.5 miles downstream.

       In February 1989, two small spills occurred.  On February 23, untreated water se.
out of a surge tank due to a faulty discharge nipple.  The nipple was replaced the followir
On February 24,  a corroded metal pipe discharged  untreated reservoir seepage contaim;

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                                                                       California
traces of cyanide, high levels of copper, and a low pH at 2-3 gallons per minute for several
hours.

Regulatory Action/Response: On February 23, 1983, after discovery of the dam seepage,
the California Regional Water Quality Control Board (CRWQCB) issued Cleanup and
Abatement Order No. 83-27. The Board issued a Cease and Desist Order (No. 83-55) in
September after five months of public hearings and monitoring, citing Noranda with discharging
hazardous waste in violation of its original permit. On October 26, 1983, Noranda paid the
CRWQCB $8,233.34 in fines in lieu of action by the State Attorney General. A new WDR
permit, Order No. 84-49, was issued May 31, 1984, deferring action on the previous Cease and
Desist Order. On July 26, 1984, however, a new Cease and Desist Order was issued (No. 84-
49) specifying new dates for controlling dam seepage.

       In July 1986, Noranda was fined $12,000 as part of an Administrative Civil Liability for its
June 8-9, 1986, spill.

       In February  1987, Noranda applied to the Department of Health Services for a
classification of its tailings as non-hazardous waste. The request was denied.

No comments were received on this damage summary.

References: U.S. EPA. Draft. Mining Waste Releases and Environmental Effects Summaries
for the State of California.  March 1994.

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California
             Iron Mountain Mine:  Uncontrolled Release
                            Kills 200,000 Salmon
   Sectors:  Copper, gold, silver, and zinc

   Facility:  Iron Mountain Mine, CA

   Facility Overview:  Iron Mountain Mine extracted copper, silver, gold, zinc, and pyrite
   minerals from 1865 to 1963, when all mining at the site was discontinued. In recent
   years, metal recovery activity at the site has been limited to extracting copper from acid
   mine drainage using copper cementation.
Waste Stream(s):  Tailings.

Waste Management Practices: Copper and pyrite ore tailings from a copper flotation mill
operated between 1914 and 1919 were disposed at a facility in the Town of Minnesota,
approximately two miles east of the site. A tailings dam was constructed in Slickrock Creek in
the late 1920s; it was destroyed by a flood in 1933.  Open-pit mining of gold and silver in the
Old Mine area resulted in tailings disposal in Hogtown Gulch, adjacent to Slickrock Creek. A
cyanide leach plant was built in this area in 1929. In 1963, the Spring Creek Debris Dam was
built to control the discharge of contaminated run-off into the Sacramento River. Releases from
Spring Creek Reservoir were coordinated, when possible, with releases from Shasta Lake to-
dilute the heavy metals.

Type of Impact/Media Affected: Sources of pollutants from the site included the cementation
plants, tailings piles, waste rock dumps, and seeps. Tailings in the Minnesota Flats area
contributed to contamination of Fiat Creek. Acid mine drainage was created by the infiltration of
rain water and the migration of ground water through the massive sulfide mineral zone. As the
water passed through the ore, sulfuric acid was produced. Copper, zinc, and cadmium were
leached from the mineralized zone by the acidic water (pH of 0.5). The acid mine drainage was
eventually discharged through mine exits or by ground water seepage into streams in the
Spring Creek watershed. In general, acid mine drainage generation was seasonal and was
accelerated during periods of heavy rainfall.

       Surface water pollution resulted in heavy metal bioaccumulation in fish and
contamination of the Sacramento River, Redding's drinking water supply. As a result of surface
water and ground water discharges, Slickrock Creek, Boulder Creek, and Flat Creek were
devoid of aquatic life. In addition, heavy rains in 1969 caused uncontrolled releases of
contaminated water from Spring Creek Reservoir which  killed approximately 200,000 salmon.
Acid mine drainage from Iron Mountain Mine was one cause of a  drastic decline in King Salmon
as well.

Regulatory Action/Response: Initial concern about pollution of the site started as early as
1902, when property owners and the U.S. Forest Reserve sued the mine owner, Mountain

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                                                                      California
Copper, for vegetation destruction caused by the Keswick Copper Smelter. Concern for the
watershed destruction began in 1928, when the California Fish and Game Commission filed
complaints about the Slickrock Creek Tailings Dam.

       A Record of Decision in 1986 authorized interim remedial actions of capping, surface
water diversion, and enlargement of the Spring Creek Debris Dam. EPA issued two Unilateral
Orders, the first was an order for temporary treatment in 1989. The second order required the
Potentially Responsible Parties to perform remedial actions in Upper Spring Creek.

No comments were received on this damage summary.

References: U.S. EPA. Draft Final. Mining Sites on the National Priorities List: NPL Site
Summary Reports. Volume II.  June 21, 1991.

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California
          Jamestown  Mine:  Plagued by Numerous Spills
   Sector: Gold

   Facility: Jamestown Mine, operated by Sonora Mining Corporation and Pathfinder Gold,
   Tuolomne County, CA

   Facility Overview: The gold mining operation and mineral extraction facility began
   operating in 1986. Units at the site included the mill, four open mine pits, waste rock
   piles, low-grade ore storage piles, a tailings management system, interconnecting
   roadways, and ancillary facilities.
Waste Stream(s): Waste rock, tailings, and spent leaching solution.

Waste Management Practices:  Four to 7,000 tons of ore per day were crushed and
concentrated at the mill. The concentrate was either vat leached on-site or transported to other
Sonora Mining facilities for processing. Crushed ore was separated into concentrate ore and
tailings using a standard flotation method.  Gold was removed from the concentrate in the vat
leaching system using thiourea and other reagents, excluding cyanide and mercury. According
to Sonora, only cyanide was used in the leaching process. Leached and flotation tailings were
disposed of in the tailings management facility, which consisted of a tailings pond, complete
with drainage equipment and liners, and an associated retention pond. Sonora reports that
none of this leaching was done on site. Water in the retention pond was treated and
discharged to surface waters under an NPDES permit (NPDES permit No. CA0081698,
CRWQCB Order No. 88-110).

Type of Impact/Media Affected: Numerous spills and releases have occurred at the site
including the following:

      •      Spills within the mill building that were not contained by the building:

                   Approximately 500 gallons of flotation solution were spilled on
                   January 2,  1987, with 200 gallons flowing out of the building into a
                   sediment pond.  Samples taken that day indicated concentrations
                   of the flotation compounds were below detectable levels.
                   According to Sonora, no releases to the pond occurred.

                   A fire on  January 16, 1987, occurred at the reagent day tank area
                   of the mill.  All electrical power to the mill was shut off. The fire
                   damaged tanks  and  pipes carrying various reagents, causing
                   them to leak. While  most of the solutions were contained within
                   the building, 2,700 gallons escaped, but were captured in a
                   temporary earthen sump.

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                                                                        California
       •      Spills that have occurred on mine property as a result of equipment
             failure:

                    A 1,000 gallon release of process water on May 7, 1989.  The spill
                    was contained quickly, with no reported environmental damage.

                    Approximately 1,500 to 2,000 gallons of tailings slurry were
                    released on July 10, 1990 when an emergency diversion system
                    for the tailings line became over-pressurized. This spill was
                    contained on-site.

                    A soda ash mixing tank overflowed on July 21, 1990, spilling
                    approximately 3,000 gallons of 1.5 percent soda ash solution into
                    a tailings pond.

                    A leak was discovered in a buried high pressure line carrying
                    filtered process water on September 6, 1990. Approximately
                    1,500 gallons were released before the line was repaired.

       •      Spills have also occurred at the tailings management facility and from
             trucks transporting materials from the mine for processing elsewhere.

       In all cases, the mechanical causes of the spills have been repaired or replaced. All
waste have been contained and returned to the site; all water was collected by sumps and
returned to the appropriate portion of the facility.

Regulatory Action/Response: No information was gathered on any regulatory actions taken
as a result of these spills.

Comments were received on this damage summary.  See Appendix A for comment listing and
Agency response.

References:  U.S. EPA.  Draft.  Mining Waste Releases and Environmental Effects Summaries
for the State of California.  1994.

Sonora Mining Company.  Comments to Phase IV Proposed Rule on Land Disposal Restriction
to Mineral Processing Wastes. 1996.

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California
    Mount Diablo Mine:  Mercury From Mine Found in Local
                                Streams, Park
   Sector: Mercury

   Facility: Mount Diablo Mine, bordering Mount Diablo State Park, Contra Costa County,
   CA

   Facility Overview: The facility conducted mining and milling from the late 1920s through
   the late 1950s. The site consisted of tailings, overburden, waste rock piles, and three
   ponds.  Tailings and overburden were also found on adjacent park land.
Waste Stream(s): Tailings, waste rock, and mine water.

Waste Management Practices: No information was gathered on the specific types of waste
management practices that had occurred at the site.

Type of Impact/Media Affected: Run-off from tailings and waste rock entered directly into the
ponds as well as into adjacent Horse and Dunn Creeks. Environmental impacts from the facility
had been documented since the late 1970s. During an inspection by State Department of Fish
and Game personnel in July 1978, the owner indicated his intent to divert spring water from the
tailings and overburden storage areas and discharge it into Dunn Creek.  State officials advised
the owner such action would violate state laws. At a follow-up inspection the next month,
however, the California illegal discharge was observed and noted as being "extremely lethal."
The owner submitted a plan to comply with regulations. A Clean-up and Abatement Order
requiring cessation of the discharge was ordered November 20, 1978.  No information was
gathered to indicate whether the deadline was met.

      On March 9,1988, and July  14, 1988, the state took samples from Horse Creek along
the border between the mine and park property. The sample  revealed near hazardous levels of
mercury, resulting from seepage and run-off from the tailings, waste rock, and overburden. In
addition, the soil was discolored (red from iron oxides, yellow from sulfur), the air smelled of
sulfur, and the creek frothed,  probably from  iron flocculation.  This iron was likely leached from
the tailings and overburden.

      During a 1989 state sampling inspection, the main pond had a pH level of 3.01.
Although an outlet to a connecting pond was constructed to reduce the possibility that the main
pond would overflow, state officials worried that a heavy rain could result in the pond
overflowing into Horse and Dunn Creek, causing adverse environmental effects.

Regulatory Action/Response:  California issued a Clean-up and Abatement Order in
response to the unpermitted discharges observed in 1978. During 1988-1989, the California
Water Quality Control Board was working with  both the owner and the Department of Parks and

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                                                                     California
Recreation to address the contamination. No information was gathered on any enforcement
actions taken during this period.

No comments were received on this damage summary.

References: U.S. EPA. Draft.  Mining Waste Releases and Environmental Effects Summaries
for the State of California.  March 1994.

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California
                      Mountain Pass Mine and  Mill:
           Lanthanide Mine Contaminating Ground Water
   Sector: Lanthanide

   Facility: Mountain Pass Mine and Mill, Molycorp Incorporated, San Bernardino County,
   CA

   Facility Overview: The site had been operating as an open pit lanthanide mining,
   beneficiation, and processing facility since 1950. Mine waste (overburden) was held on-
   site, and numerous process water, tailings, and product storage ponds were operated.
Waste Stream(s): Process water and tailings.

Waste Management Practices: Mine waste overburden was stockpiled on-site.  From 1950 to
1980, wastewater from the mill was disposed of in on-site percolation-type surface
impoundments.  In 1980, two 40-acre evaporation ponds were constructed on Ivanpah Dry
Lake.

Type of Impact/Media Affected: Ground water samples taken in 1985 indicated increasing
total dissolved solids levels in the ground water below the lakebed. At that time the evaporation
ponds were determined to be leaking, due to mechanical failure. In 1988, the leaking ponds
were replaced with a 100-acre wastewater evaporation pond. Ground water remediation was
being accomplished through installation of interceptor wells. Continuous ground water
extraction had occurred since 1980.  More wells were to be constructed. Several of the former
waste disposal ponds had been clean closed. The company was investigating methods for
sealing or reconstructing several of the active holding ponds to eliminate leakage.

      Two wastewater spills had also been documented at the site.

             On May 26,  1989, approximately 3,375 gallons spilled from a damaged
             pipeline carrying tailings water and effluent from the separation plant.
             The spill was contained in an on-site stormwater run-off pond.

      •      In late August 1990, approximately 45,000 gallons of wastewater spilled
             from a surge tank when trash from plants further up the line clogged a
             valve in the main line below the holding tank. The spill was contained by
             the facility's surface/ground water collection system.

No remedial measures had been proposed to correct any contamination caused by the two
surface spills, as these spills were contained on-site and not believed to pose a significant
threat to human health or the environment.

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                                                                     California
Regulatory Action/Response: On November 4, 1985, the California Regional Water Quality
Board notified Molycorp that certain surface impoundments on-site contained hazardous waste
and were covered under the Toxic Pits Cleanup Act (TPCA). As of 1994, only the surge pond
had been determined to be covered by TPCA.

No comments were received on this damage summary.

References: U.S. EPA. Draft.  Mining Waste Releases and Environmental Effects Summaries
for the State of California.  March 1994.

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 California
                         Pine Creek:  Tungsten Mill
                  Leaks Pollutants into Nearby Stream
   Sector: Tungsten

   Facility:  Pine Creek Operations, U.S. Tungsten Corporation, Inyo County, CA

   Facility Overview:  This site conducted tungsten mining and milling, including crushing
   and grinding ore, flotation concentration, pressure leaching, molybdenum precipitation,
   solvent extraction, and ammonium paratungstate precipitation.
 Waste Stream(s):  Boiler blowdown, tungsten mill tailings, and wastewater.

 Waste Management Practices: Mine drainage was used for mill make-up water.         ~  '
 Approximately 1.5 million gallons per day of tailings were discharged from the mill to four
 tailings ponds. Effluent from several septic tanks located throughout the mill site were added to
 the tailings discharge.  An additional 2,500 gallons per day of boiler blowdown were added to
 the tailings discharge.  The four tailings ponds, covering 90 acres between Pine Creek and the
 northern canyon wall, were unlined and contained more than 15 million tons of tailings
 deposited over more than 40 years. Also, an unlined decant pond and three percolation ponds
 received decant water from the tailings ponds.

 Type of Impact/Media Affected: On February 21, 1990, routine sampling and analysis of the
 receiving waters of the Pine Creek Drainage showed an increase in the amount of total
 dissolved  solids (TDS). In response to the finding, U.S. Tungsten profiled the entire stream to
 determine the source of the problem.  This effort revealed that sodium and sulfate, major
 elements  of U.S. Tungsten's waste stream from the ammonium paratungstate plant,  were the
 primary contributors. The company determined that there was a leak in an underground
 distribution line but was unable to determine the duration of the problem. They did, however,
 estimate that 2,419 gallons per day, or 2,622 pounds per day of TDS, were being released to
 Pine Creek.  A spill report was filed by U.S. Tungsten on March 6, 1990, with  an addendum
 filed on March-It.

       All waste stream flow from the leaking distribution line was stopped, and the line was
 filled with  concrete. A monitoring program was implemented until April 11,  1990, when TDS
 levels returned to meeting limits set forth in the basin plan.

 Regulatory Action/Response: No information was gathered on any regulatory actions taken
 at this facility.

 Comments were received on this damage summary.  See Appendix A for comment listing and
'Agency response.

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                                                                     California
References: U.S. EPA.  Draft.  Mining Waste Releases and Environmental Effects Summaries
for the State of California. March 1994.

U.S. Tungsten. Comments on Phase IV Proposed Rule on Land Disposal Restriction to Mineral
Processing Wastes. 1996.

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California
                               U.S. Borax Mine:
                          Polluting Ground Water
   Sectors:  Borax/borate

   Facility: U.S. Borax Mine, Kern County, CA

   Facility Overview:  U.S. Borax operated a borax mine, a refinery, and a boric acid plant.
   The facility included 13 surface impoundments for evaporation and precipitation of
   recoverable secondary sodium borate and other constituents.
Waste Stream(s): Process wastewater and solids.

Waste Management Practices:  Waste liquids and solids from the refinery and boric acid pjartf
were pumped to surface impoundments for evaporation and precipitation of secondary sodium
borate and other constituents. Of the 13 impoundments at the facility, three were unlined, five
had clay liners, and five were fully lined. Past disposal practices allowed wastewater in these
impoundments to overflow the clay lined (or unlined) surfaces and percolate through the upper
portions of the dikes.

Type of Impact/Media Affected: Releases to ground water from the impoundments were
discovered in 1975. Wastewater  had migrated into the vadose zone, resulting in saturated
conditions below the units.

       CRWQCB Order No. 6-90-37, issued March 9, 1990, required U.S. Borax to conduct
quarterly ground water monitoring. Results from the 1990 third quarter indicated total dissolved
solids (TDS) concentrations underlying  the units exceeding background levels by up to three
orders of magnitude, in some cases exceeding 4,000 mg/L. Arsenic concentrations in on-site
ground water exceed the MCL standard of 0.05 mg/L.

       On July 30, 1990, a spill occurred at the facility as a result of an 8 to 10 inch lengthwise
split in a section of underground piping  used to pump wastes to the surface impoundments.
Arsenic-bearing waste bubbled to the surface into a shallow ditch. This release continued for
an extended, though unspecified,  period of time at a rate of 300 gallons per minute.  A vacuum
truck was used to recover 42,000 gallons of wastewater, while the soil was to be sampled and
returned to the refinery for borate  recovery. No data were gathered on whether these actions
were actually taken.

       In 1985, the unlined ponds were taken out of service. All impoundments being used at
the site had clay liners. In  addition, subdrains lay below the liners; they discharged to leachate
collection sumps. As of 1994, there were no known releases to the vadose zone or ground
water.

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                                                                       California
       A series of interceptor wells were installed in 1985 approximately Vz mile downgradient
of the facility.  Continuous pumping of these wells stopped in 1989 when hydrogeologic testing
determined that the perched ground water mound was being pulled rather than intercepted.

Regulatory Action/Response: A Compliant/Spill Report Form was filed by the Kern County
Fire Department for the 1990 spill. U.S. Borax submitted a follow-up report to the county.  No
further regulatory actions were taken as a result of this incident.  U.S. Borax reports that
monitoring wells and ground water extraction wells have been installed to contain the
contamination and begin to reduce the contamination level.

Comments were received on this damage summary.  See Appendix A for comment listing and
Agency response.

References:  U.S. EPA.  Draft.  Mining Waste Releases and Environmental Effects Summaries
for the State of California.  March 1994.

U.S. Borax. Comments on Phase IV Proposed Rule on Land Disposal Restriction to Mineral
Processing Wastes.  1996.

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Colorado
                               ASARCO Globe:
                Metals  Polluted Ground Water and Soil
    Sectors: Antimony, cadmium, copper, gold, lead, indium, silver, tellurium, and thallium

    Facility: Globe Paint, ASARCO, Denver, CO

    Facility Overview: Smelter operations began in  1886 producing gold, silver, lead, and
    copper. In 1901, the plant was converted to lead  smelting. In 1921, lead smelting was
    replaced by arsenic trioxide production, which continued until 1926.  The plant was then
    converted to produce cadmium, litharge, test lead, and occasionally thallium, indium, and
    other high purity metals such as antimony, copper, and tellurium. Cadmium production
    ceased in 1993.
Waste Stream(s): Slag and process wastewater.                                    -  .

Waste Management Practices: Liquid and solid wastes were initially disposed at several
locations on the site, generally near where they were generated, as fill material, in piles, and as
liquid discharge to the ground surface or to a sedimentation pond. From approximately 1901 to
1919,  lead blast furnace slag was disposed in the northeast comer of the site.  During the
1930s, spent electrolyte solution may have been discharged directly to the ground surface on-
site.  Between 1948 and 1986, liquid wastes were discharged to the Former Neutralization
Pond. Until 1993, process wastewater was treated on-site and discharged to the Denver Metro
Wastewater utility sanitary sewer system.  ASARCO has recently maintained an on-site
treatment facility for ground water.  After treatment, the ground water has been discharged to
the Denver Metro Wastewater utility sanitary sewer system. Sludge from treated ground water
was shipped off-site to ASARCO's East Helena (MT) site.

Type of Impact/Media Affected: The approximately 89 acre site is situated along the west
edge of the South Platte River floodplain.  Although most of the site is between 30 and 60 feet
above the floodplain, the slag deposit was located in the floodplain. The slag deposit was
approximately 15 feet  thick, up to 300 feet wide, and 1,100 feet long. The precipitates, which
were disposed of and  have formed sediments in the Former Neutralization Pond, ranged from
11 to 17 feet in thickness and covered approximately 7 acres. According to comments by
ASARCO, the slag did not contribute to any environmental concerns.

      Sitewide, the contaminants of concern that were released to soil and ground water were
arsenic,  cadmium, lead, and zinc. Much of the shallow ground water beneath the site contained
elevated concentrations of dissolved cadmium and zinc. Although the surficial ground water
was not  a source of municipal drinking water, several domestic wells in the vicinity were
contaminated.
      Sources of contamination included the fill materials, the former sedimentation pond, and
the Former Neutralization Pond. A smaller arsenic plume coincided with the location of the

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                                                                       Colorado
former arsenic production facility. Another localized arsenic plume was detected below the
precipitate in the Former Neutralization Pond. Surface water and sediments in on-site retention
ponds were contaminated from ground water seepage.

       Shallow soil, both on and off-site, had concentrations of cadmium, arsenic, lead, and
zinc exceeding background levels. Although these levels decreased with depth and distance
from the site, they were perceived as presenting a potential health hazard to the nearby public,
Globeville community, especially children.  Within one mile of the site, concentrations of these
metals in vegetable garden soils were typically elevated.

Regulatory Action/Response: In 1980 and 1981, the Colorado Department of Health (CDH)
found the site to be out of compliance with the Colorado Solid Waste Disposal Sites and
Facilities Act.  EPA listed the site on the open dump inventory for 1981 under RCRA Section
4000 criteria.  In December 1983, CDH sued ASARCO for damages to natural resources under
CERCLA.  In 1986, CDH issued an Administrative Compliance Order (CO) against ASARCO
alleging violations under the Colorado Hazardous Waste Management Act. The CO was
resolved in 1987 under a Compliance Order Upon Consent. Later in 1987, the State and
ASARCO entered into a Memorandum of Agreement (MOA) to conduct joint studies to assess
cleanup of the site.

       In March 1992, the State and ASARCO entered into an Agreement in
Principle/Principles of Agreement (AIP/POA) which superseded the MOA and set forth a
proposal for ASARCO to remediate the site and pay for past and future state costs and damage
to natural resources. In July 1993, the United States District Court in Denver issued a Consent
Decree that superceded the AIP/POA and included the stipulations and other agreed-upon
elements for cleanup as stated in previous documents, studies and investigations.

       Actions taken to date have included capping the Former Neutralization Pond in 1986,
constructing a new wastewater treatment plant in 1986, repairs to the Farmers and Gardeners
Ditch in 1987 and 1988, and constructing a ground water interceptor drain in 1988. According
to comments by ASARCO, two seasons of community soils remediation have been completed,
a medical monitoring program has been implemented and the Industrial Drainage Ditch has
been remediated. Also according to ASARCO, plant site soils with elevated concentrations of
lead, cadmium and arsenic have been capped and the interceptor trench has been backfilled.
Additionally, a large, local housing project nearby was closed and its residents relocated due to
contaminated soils. According to ASARCO, the project was closed for a number of reasons,
including financial resources, age and condition of the facility (i.e. lead paint and asbestos),
proximity to an interstate highway expansion project, and occupancy issues.

Comments were received on this damage summary.  See Appendix A for comment listing and
Agency response.

References:  Record of Decision, Asarco Globe Plant Site  Denver, Colorado. Colorado
Department of Health, February 18,  1993.

Globeville Childhood Metals Study: An Exposure Study Denver, CO. Colorado Department of
Health Division of Disease Control and Environmental Epidemiology, February 1994.

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Colorado
Public Health Evaluation.  Colorado Department of Health, undated.

ASARCO. Comments to Phase IV Proposed Rule on Land Disposal Restriction to Mineral
Processing Wastes.  1996.

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                                                                       Colorado
             Clear Creek:  Old Mine Waste Tunnels and
                Tailings Erosion  Cause Contamination
  Sector: Gold

  Facility: Clear Creek, Central City, Clear Creek and Gibsin Counties, CO

  Facility Overview: Gold mining activity began in 1859 with the discovery of placer gold
  at the mouth of Chicago Creek, a tributary to Clear Creek.  By the summer of 1860,
  almost all surface lodes  had been claimed.
Waste Stream(s): Acid mine drainage, mine waste, and tailings piles.

Waste Management Practices: Waste management practices included disposing of waste  .
and tailings piles near where they were generated, and allowing mine drainage water to flow
into existing surface water features. As a result of extensive mining activity on a large number
of small mining claims, wastes were disposed in numerous small-volume waste rock and
tailings piles distributed over a wide area. In addition, a large number of tunnels drained water
from the mines.

Type of Impact/Media Affected: Surface waters at the site were contaminated by direct
discharges from both mine drainage tunnels and eroding mine waste piles. Contaminants have
included aluminum, arsenic, cadmium, chromium, copper, fluoride, lead, manganese, nickel,
silver, zinc, and the indicator pH. The presence and concentration of these contaminants has
varied over time and location within the site. Contaminated areas have included North and
West Clear Creek, Chicago Creek,  Lion Creek, and Soda Creek.

      Ground water samples taken from 14 drinking water wells and 19 monitoring wells in the
area indicated elevated concentrations of metals at many locations. Several of the monitoring
wells and one of the drinking water wells contained concentrations that exceeded drinking water
standards. Both soil and air quality were contaminated by tailings piles, sedimentation from
runoff, and airborne dust. These impacts were generally localized and occurred  near mine
waste and taHings piles.

Regulatory Action/Response: Removal actions have included emergency installation of a
retaining wall to support a tailings pile, removal of several tailings piles and contaminated soil
and sediment, control of acid mine  drainage, and provision of bottled water to several homes
that used contaminated water. These homes were later connected to a municipal water supply
system.  Remedial actions completed to date  include erosion and stormwater controls, slope
stabilization, streambank removals, and capping of tailings, all at various locations within the
site:

No comments were received on this damage summary.

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Colorado
References:
Record of Decision Clear Creek/Central City Superfund Site Operable Unit #3 Gilpin and Clear
Creek Counties, Colorado. United States Environmental Protection Agency Region VIII and
Colorado Department of Health, September 30, 1991.

Argo Tunnel Site Inspections/Progress Reports. Colorado Department of Public Health and
Environment.

National Tunnel Site Inspections/Progress Reports. Colorado Department of Public Health and
Environment.

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                                                                      Colorado
                                 Climax Mine:
             Molybdenum Mine Tailings Blown Off-Site
   Sector: Molybdenum

   Facility: Climax Mine, AMAX Mineral Resources Company, Lake, Eagle, Summit, and
   Park Counties, CO

   Facility Overview:  The Climax Mine produced molybdenum disulfide from molybdenite
   ore, primarily from an open pit. The site covered approximately 11,600 acres of
   contiguous land, though it had operated at a very small percentage of its capacity. Site
   operations began in 1918.
Waste Stream(s): Tailings.

Waste Management Practices: Tailings from flotation were transported in a water slurry via
tailings pipelines to ponds located north of the mill. After entering the ponds, tailings sands
settled out, the water was decanted, and then pumped back to the mill as part of the recycled
water circuit. The tailings were comprised mostly of silica.

Type of Impact/Media Affected: High winds had carried loose tailings dust from the
impoundments and dam off-site, causing poor visibility and tailings accumulations. The
phenomena had been called a "horizon white-out."

Regulatory Action/Response: On December 2, 1986, the Colorado Mined Land Reclamation
Board issued NOV Number M-86-085 to AMAX, and ordered AMAX to continue to stabilize the
ponds and dams and to submit a tailings stabilization plan. Two inspections and citizen reports
were used as evidence in citing AMAX with violating the terms of its operating permit (#M-77-
493) as well as C.R.S. 34-32-116 (1)0). AMAX was ordered to work with the Colorado
Department of Health and the Mined Lands Reclamation Division to stabilize the problem areas
and submit a stabilization plan within 60 days. A civil penalty was also levied in the amount of
$4,000, but a subsequent settlement agreement dropped the fine. An Agreement, Stipulation,
and Order dated December 18, 1986, vacated the original NOV and waived the fine. Instead,
AMAX was ordered to submit an application to incorporate their October 30, 1986, control plan
to their permit. AMAX submitted a revised dust suppression control plan with the  long-term
goal of treating and revegetating areas for stabilization.

Comments were received on this damage summary.  See Appendix A for comment listing and
Agency response.

References: U.S. EPA.  Draft.  Mining Waste Release and Environmental Effects Summary for
the State of Colorado. March 1994.

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Colorado
Cyprus Amax, Comments to Phase IV Proposed Rule on Land Disposal Restriction to Mineral
Processing Wastes. 1996

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Colorado

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Colorado
                              Denver Radium:
    Gold and Silver Mining Wastes Heavily Contaminate Soil
  Sectors: Gold and silver

  Facility: Denver Radium (Robinson Brick), Denver, CO

  Facility Overview: In 1886, the Bailey Smelter began operation on this site. In 1890, the
  Gold and Silver Extraction Company established a mill and laboratory to process ore. In
  1902, the Colorado Zinc Company constructed a mill which .operated until 1911.  In 1913,
  the National Radium Institute began milling operations which continued through 1918.
Waste Stream(s):  Radium contaminated wastes and dusts.

Waste Management Practices:  The site includes approximately 31 properties where radium
contaminated waste was discarded when the facility closed. A total of approximately 106,485
cubic yards of contaminated soil was left behind. In 1988, excavation and permanent off-site
disposal of contaminated materials began.  As of January 1991,  149,592 tons (out of an
estimated 287,060 tons) had been disposed of at a commercial facility.

Type of Impact/Media Affected:  The maximum level of radium found in the contaminated soil
was 5,093 pCi/g. Soil from six properties also exhibited Extraction Procedure (EP) toxicity for
metals, total levels of polynuclear aromatic hydrocarbons (PAHs), and total levels of volatile
organic compounds (VOCs). Other contaminants of concern included radium and radon.

Regulatory Action/Response:  The site was placed on the NPL in 1983. Initial remedial
investigations were initiated in 1981, and completed in 1982. The final Remedial
Investigation/Feasibility Study (RI/FS) was completed in 1985. Seven Records of Decision
(RODs) for 10 of the 11 Operable Units were signed in 1986 and in 1987.

No comments were received on this comment summary.

References: U.S. EPA.  Draft Final. Mining Sites on the National Priorities List:  NPL Site
Summary Reports,  Volume II. June 21, 1991.

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Colorado

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Colorado
                 Idarado Mine:  Millsite Areas Used for
                        Hazardous Waste Disposal
   Sector:  Copper, gold, lead, silver, and zinc.

   Facility: Idarado Mine, San Miguel, Ouray, and San Juan Counties, CO

   Facility Overview:  From 1956 until Idarado's mining operations were closed in 1978, all
   ore was transported through the Treasury and Mill Level Tunnels and milled near Telluride
   at the Pandora Mill.  Zinc, copper, lead, silver, and gold were produced.  In 1978,
   depressed metal prices necessitated cessation of Idarado's operations.
Waste Stream(s):  Tailings, mine drainage, fire-assay slag, cupels, waste rock, and various
chemicals.

Waste Management Practices: The site has three distinct natural areas:  the Telluride Valley,
where the Pandora Mill was located; the Red Mountain Mine; and the High  Country between
the two. The Telluride Valley contained four infiltration lagoons, four consecutive unlined
tailings piles, and one combined, unlined tailings pile. This combined pile was sprinkled with
water as a part of Idarado's dust control program.  The tailings piles contained deposits of
ground mine rock that remained after most of the valuable metals had been removed by milling.
The lower end of the Telluride Valley, in an area known as Society Turn, encompassed more
tailings piles. The Red Mountain Valley portion of the mine contained four tailings piles
adjacent to Red Mountain Creek.  The  Red Mountain Valley also included buried tailings, the
"Treasury Tunnel" mine portal, several other scattered mines, tailings piles, mine waste rock
piles, and portals.  The High Country consisted of scattered waste rock piles,  portals and relics
of past mining activities by prior owners or occupants.

       Eight waste sources in both millsite areas were designated in 1985 after PCS
contaminated soils were found.  Wastes such as fire-assay slag, cupels, and barrels of various
chemicals were excavated and shipped off-site. Tailings material was also  disposed of at both
sites, and used as fill in the Town of Telluride on properties and as ditch linings when sewer and
water lines were laid.

Type of Impact/Media Affected: Precipitation flowed across and through the tailings piles,
causing erosion and deposition of metals in the area's ground water, rivers, and creeks. Water
also flowed from mine portals and crossed waste piles, where it picked up metals and other
hazardous materials on its downward course, ultimately carrying metals and other hazardous
constituents into the area's streams and sediments.  Concentrations of zinc, cadmium, and
copper in the San Miguel River were relatively  low upstream but increased downstream past
the Pandora Mill site. The high zinc concentration and the other heavy metals in the surface
water and sediments in the San Miguel River caused significant degradation of the water quality
as a habitat for aquatic life. Plant life density in the San Miguel River also decreased

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                                                                         Colorado
substantially downstream from the Telluride tailings piles, and this too was attributed to the
presence of heavy metals.

       The Telluride tailings piles were also continually eroded by wind.  Blowing tailings
contaminated soils and surface water with cadmium, lead, zinc, and copper. Tailings were
blown into the Town of Telluride, producing a whitish-gray dust cloud that deteriorated the air
quality.  In addition, testing on the combined tailings pile indicated EP toxicity.

       The three Society Turn tailings piles were situated in the San Miguel River.  Sediments
in the stream were contaminated with cadmium, lead, silver, and  zinc, affecting the aquatic life
in the area.

       The Red Mountain tailings contaminated Red Mountain Creek with lead, cadmium,
copper, silver, and zinc like the Telluride tailings contaminated the San Miguel River. In
addition, non-point metals loading contributed to contamination of Red  Mountain Creek,
particularly near the buried tailings pile.  No fish were found in the Creek, and plant life density
was significantly reduced.

       Discharge from mine portals and waste rock piles also contributed to the poor water
quality of the streams in the Telluride and Red Mountain sides of the mine.

Regulatory Action/Response: In 1984, the State of Colorado began  a Remedial Investigation
and Feasibility Study, followed by a Preliminary Record of Decision, and finally a Record of
Decision issued by the Colorado Department of Health.  The United States District Court found
that the Idarado Mining Company was required to implement a remediation plan that included
stabilizing and capping the Telluride and Red Mountain tailings piles, moving and consolidating
the Society Turn tailings piles, implementing a lead screening study in the community, plugging
and diverting water from the mine portals, and remediating the millsites.

No comments were received on this comment summary.

References:  707 F. Supp. 1227.  State of Colorado v. Idarado Mining Company., et a/., No. 83-
C-2385. United States District Court, D., CO.  February 22, 1989.

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Colorado
                              Lincoln Park Site:
                    Ground Water Injurious to Cattle
   Sectors:  Uranium, thorium, vanadium, molybdenum

   Facility: Lincoln Park Site, Cotter Corporation, Fremont County, CO

   Facility Overview: The facility processed uranium ore into yellow cake from 1958 until
   1986, when operations ceased. Alkali mining was conducted until  1979, when the acid
   milling process began.
Waste Stream(s): Tailings, uranium ore stockpile, raffinate, and spent sulfuric acid stockpiles.

Waste Management Practices:  In 1971, a Soil Conservation Service (SCS) flood control dam
was built in Sand Creek, about 4,000 feet north of the main tailings impoundment, to mitigate
the effects of storm-generated floods. Prior to the dam's construction, storm water run-off from
the Mill site flowed down Sand Creek to Lincoln Park and eventually into the Arkansas River.
This run-off and contaminated ground water from springs and seeps in the Sand Creek channel
were impounded and isolated from Lincoln Park and the Arkansas River.  Cotter Corporation
withdrew contaminated, impounded water and pumped it to the primary, lined impoundment.
As part of the 1988 State cleanup mentioned below, a cut-off barrier was established at the site
of the dam to prevent ground water flow beneath the dam.

      During the milling process, molybdenum and vanadium were recovered as by-products
during uranium concentrate production. During the period of alkali milling (prior to 1979), 10
ponds were used for storage of process liquid and fresh water, disposal of tailings, and storage
of fresh water.  Seven of the 10 ponds were unlined.  In 1979, when the acid milling process
began, a double-lined  impoundment was installed with drains above the synthetic membrane
and below the clay layer and synthetic membrane.  Tailings from this acid leach process and
water collected from ground water interceptors were stored in this impoundment.  It consisted of
two units:  (1)-a primary impoundment storing acid leach mill wastes, and (2) a secondary
impoundment  Between April 1981 and August 1983, the contents of six  of the ponds (2.2
million cubic yards of tailings) were moved to a double-lined secondary impoundment. Two
other  ponds were moved in 1978 during construction of the secondary impoundment.

      The Mill occasionally processed custom ores such as waste raffinate from other mills
and precipitates or slags from other processes. In one  instance, PCB-contaminated ore was
processed, which contaminated some of the plant areas. Trichloroethylene was used to extract
the PCBs from the contaminated soils. In addition, a catalyst plant on the Mill site was operated
briefly in 1978 and 1979 to recover metal values from spent catalyst material.  The spent
sulfuric acid was stockpiled on-site.

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                                                                         Colorado
Type of Impact/Media Affected: Sources of contamination included the uranium ore stockpile,
leakage from the old tailings areas, and the soils and rocks beneath the old tailings ponds.
Contaminated ground water at the site flowed downgradient into the Lincoln Park area.
Molybdenum concentrations were identified as being injurious to cattle and unsuitable for
irrigating crops used for cattle feed.  A contaminant plume of uranium and molybdenum
extended from the site into the Arkansas River. Maximum concentrations of lead and selenium,
as well as gross alpha and beta, exceeded maximum contaminant levels for drinking water.

       Emissions of radionuclides and hazardous metals were measured through air and soil
sampling. Wind transport of contaminants resulted in off-site soil concentrations of metals at or
above a level of concern for agriculture use, cattle grazing, and wildlife. In particular, soil
concentrations were above critical values for  molybdenum, cobalt,  nickel,  arsenic, copper, zinc,
and cadmium.  In general, contamination decreased with distance from the site.  Contaminated
off-site soils were also entrained in surface flow, and contaminants were transported in the
intermittent streams to the Arkansas River.

       Off-site vegetation samples also have been contaminated at levels toxic to plants and/or
animals.

Regulatory Action/Response:  The Atomic Energy Commission (AEC) was the regulatory"
agency responsible for oversight of the facility from 1958 to 1968.  Between 1959 and 1966, the
AEC cited the site 18 times for failing to track radioactive releases. The Colorado Department
of Health assumed regulatory oversight in 1968 and cited Cotter Corporation 82 times for
various violations under the Nuclear Regulatory Commission regulatory process between 1968
and 1984. Among the state citations were exceedances of "As Low as  Reasonably Achievable"
particulate emissions, discharge and releases from tailings discharge pipes, and poor
recordkeeping on control of off-site surface water contamination.

       The State of Colorado conducted a Remedial Investigation in 1986 to determine the
environmental characteristics and the type and extent of contamination. The site  is listed on the
NPL

No comments were received  on this comment summary.

References: U.S. EPA. Draft Final.  Mining  Sites on the National Priorities List:  NPL Site
Summary Reports. Volume III.  June 21, 1991.

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Colorado
              Ruble Heap Leach:  Releases of Cyanide
                   from Heap Leaching at Gold Mine
   Sector: Gold

   Facility: Ruble Heap Leach, American Rare Minerals (ARM), Inc., Teller County, CO

   Facility Overview: The Rubie site consisted of an open pit mine, cyanide heap leaching
   units, and associated facilities.  The site had operated intermittently since 1980.
Waste Stream(s): Spent barren solution.

Waste Management Practices: Ponds at the site included a lined pregnant solution pond, a
lined barren solution pond, a lined safety pond, and an unlined emergency overflow pond.  A  .
synthetic lined spillway connected the pregnant pond to the safety pond. Pregnant solution was
conveyed from the heap to the pregnant pond in PVC-lined ditches, which were simply
extensions of the lined pond.  After percolating through the heap, solution was directed to the
pregnant solution pond, then to carbon adsorption columns. Barren solution returned to the
barren pond, where it was fortified with cyanide and caustics.  Loaded carbon columns were
removed to the stripping plant for ethylene glycol stripping.

Type of Impact/Media Affected:  Several releases of cyanide solution had occurred, caused
by leaks from the pregnant solution pond or tears in pond and ditch liners. Instances of over
spraying of cyanide solution had occurred several times since 1985. Available information did
not indicate the volume or chemical make-up of any discharges or leaks that may have
occurred.

Regulatory Action/Response: During 1985 and  1986, four inspections by the Colorado Mined
Land Reclamation Division (MLRD) noted problems such as over spraying, liner tears, and
leaks at the site. Follow-up inspections noted that the problems were corrected. Subsequent
MLRD inspections in 1988, 1991, and 1992 found tears and improper care of liners, permit
boundary viotefens, ditch blockages, leaks, and dangerous pond levels.  On August 3,  1988,
the MLRD issued a Notice of Violation (NOV), a Cease and Desist Order, and a $2,500 civil
penalty as well as a $30,700 fine if corrective actions were not taken. On November 15, 1988,
the MLRD ordered ARM to provide additional financial warranty and informed ARM that they
were delinquent in taking corrective actions. On April 25,  1991, the MLRD issued another NOV
which cited ARM with failure to comply with the approved  mine plan for the Rubie Site.  ARM'S
request for reconsideration was granted by MLRD, which modified the Cease and Desist orders
and allowed ARM to conduct operations provided that all corrective action orders were met.

No comments were received on this comment summary.

References: U.S. EPA. Draft. Mining Waste Releases and Environmental Effects Summary
for the State of Colorado.  March 1994.

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Colorado

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Colorado

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                                                                       Colorado
                 Smeltertown:  Bottled Water Needed
                 to Replace Contaminated Well Water
   Sectors:  Lead, copper, silver, and gold

   Facility: Smeltertown, CoZinCo, Salida, Chafee County, CO

   Facility Overview: Activity began at Smeltertown in 1902 with the construction of a
   smelter and refinery for lead, gold, and silver. Operations continued until 1919. In 1920,
   the smelter was sold at auction to a timber company.  The northern part of the site was
   used by several companies (e.g., Koppers which became Beazar East, Inc. in 1990) as a
   railroad tie-treating facility between 1924 and 1953. After that time, the property changed
   ownership a few times until purchased by Butala Construction which continues to operate
   a gravel quarry on the site.  CoZinCo has operated a zinc sulfate manufacturing plant on-
   site since 1975.
Waste Stream(s): Miscellaneous smelting and refining wastes and treating wastes.

Waste Management Practices:  Areas of contamination included several drum piles, sludge
disposal and storage areas, and two wastewater lagoons. The smelting operation generated
molten slag which was disposed of along the Arkansas River to the west of the smelter. Cinder
material was also disposed of along the river directly south of the smelter. These features are
still evident at the site. Ore storage areas were reportedly located north of the smelter facility.

      During its use as a tie-treating facility, railroad ties and other lumber products were
pressure treated with creosote, stored on railroad sidings near the treatment building, and
allowed to drip. Effluent from the  process area was directed to lagoons.  More recently, surface
soil was reportedly scraped from the site and buried in six trenches on the former Koppers
property by Butala Construction.  The trenches were approximately 100 feet long and 12 to 14
feet wide.  This contaminated soil was reportedly in an area of red cinder off the former
Koppers property and adjacent to the river.

Type of Impact/Media Affected: The smelting and wood treatment wastes have contaminated
soils and ground water in the site  and vicinity.  Soils associated with smelter activities had
elevated levels of arsenic, cadmium, copper, lead, manganese, and zinc.  Surface soil metals
concentrations were highest in the smelter part of the site, and decrease downwind of the
smelter. Subsurface soil metals concentrations appeared to be related to very localized historic
activities.  The soils from both the smelter and Koppers wood-treatment area exceeded arsenic
and lead remediation concentration  levels.  The affected soils covered approximately 3.0 acres
at the smelter site and 7.8 acres at the Koppers site, for a total of 2,900 cubic yards. In
addition, soil stockpiled on-site from various EPA emergency response cleanup actions was
estimated  at 40,500 cubic yards.

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Colorado
       The wood treating contaminants included 16 creosote derived PAHs, possibly
pentachlorophenol (penta), and multiple dioxin and furan isomers. Soils contaminated with
these hazardous constituents were located at the process area, lagoons, and the area where
Butala placed removed soil.  Soil contamination  extended from about 1 to 2 feet below ground
surface to 40 feet below ground surface in some areas, thus impacting a regional alluvial
aquifer.

       Contaminated ground water extended from beneath the wood treating process area and
continued off-site.  Concentrations of PAHs in springs emanating from the site varied, generally
with seasonal fluctuations in  ground water levels. Contaminated ground water was detected
extending off-site from the lagoons and in domestic wells in the area. Metals contamination
also existed in ground water  beneath the smelting area.  Zinc concentrations exceeded the
Superfund Removal Action level of 3.0 mg/L in the area south of the smelter and CoZinCo sites.

Regulatory Action/Response: The sources of contamination were addressed under a RCRA
corrective action Order issued by the State of Colorado.  In 1986, creosote contaminated soil
was removed by Butala Construction from the former wood-treating portions of Smeltertown
and disposed of at the Chaffee County Landfill.  The  EPA investigation of this occurrence led to
the discovery of potential environmental impacts at the site.  Subsequently,  the site was
proposed for NPL listing.  The EPA issued letters to PRPs to initiate the process of further site'
investigation and removal action or remediation.

       The EPA Emergency Response Team (ERT)  conducted two site investigations to
characterize contamination posing an immediate threat to human health and the environment.
As a result of these investigations, soil was removed  from off-site residential areas and
stockpiled on-site.  In addition,  CoZinCo provided bottled water to residents downgradient of
their facility.

Comments were received on this damage summary.  See Appendix A for comment listing and
Agency response.

References:
Draft Remedial Investigation Report Former Koppers Wood Treating Site, Salida, Colorado.
ENSR Consulting and Engineering, October 1994.

Smelter Subsite Remedial Investigation Smeltertown Site Salida,  Colorado.  CH2M Hill,
November 199C

Feasibility Study Smeltertown Superfund Site. CH2M Hill, May 8, 1995.

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                                                                       Colorado
                            Smuggler Mountain:
                          Old Mine Listed on NPL
   Sectors:  Silver, lead, and zinc

   Facility: Smuggler Mountain, Pitkin County, CO

   Facility Overview: Silver, lead, and zinc were mined in the late 1800s and early 1900s.
   In the 1960s, a reprocessing facility operated at the site.
Waste Stream(s): Waste rock, tailings, and slag.

Waste Management Practices: Smuggler Mountain contained mining wastes from years of
extensive mining, milling, and smelting operations.  The site contained 110 acres of waste rock,
tailings, and slag. The bulk of the mining wastes were placed on the steep slope of the western
side of Smuggler Mountain near the Smuggler shaft from 1880 to 1915.  In the mid-1960s, the
operation of the reprocessing facility caused the dispersion of the wastes from the relatively
distinct piles at the mine shaft to other locations throughout the site.  Also, a number of settling
ponds were created around the site during reprocessing.

      Mine wastes, such as waste rock, tailings, and slag, comprised much of the site.
Approximately 2.4 million cubic yards of these waste materials were generated at the site;
however, volume estimates were uncertain.  The wastes had been spread over a wide area and
at depths varying from 1 or 2 to 40 feet. The wastes were dispersed further by subsequent
residential development.  They occurred covered, uncovered, or mixed with native soil, and
they contained high concentrations of tead and cadmium, among other constituents.

Type of Impact/Media Affected: Soil was the primary contaminated medium; however,
contaminants had been found in ground water and surface water. Both mine tailings and man-
made fill were contaminated with lead at concentrations greater than 1,000 mg/L.  Significant
amounts of cadmium had been detected in soil samples as well. Results of ground water
sampling had shown high uranium, gross alpha, total dissolved solids (TDS), and trace metal
concentrations. Residential and commercial development had occurred around the tailings
areas, posing potential human health and  environmental risks.

Regulatory Action/Response: The Smuggler Mountain site was added to the NPL in May
1986. The Operable Unit I Remedial Investigation/Feasibility Study (RI/FS) was completed in
early 1986 and amended by EPA in the same year. Using the Rl data, EPA prepared an
Endangerment Assessment. The Superfund Enforcement Decision Document, signed on
September 29, 1986, described the remedial actions to be taken at the site. Subsequent
sampling in 1988 prompted EPA to change the selected remedy for Operable Unit 1 and
postpone re-evaluating the remedy for Operable Unit 2 until a Remedial Investigation/Feasibility
Study was completed.

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Colorado
No comments were received on this comment summary.

References:  U.S. EPA. Draft Final. Mining Sites on the National Priorities List: NPL Site
Summary Reports.  Volume IV. June 21, 1991.

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                                                                       Colorado
  Urad Mine and Mill:  Tailings Drainage Contaminates Creek
   Sector: Molybdenum

   Facility: Urad Mine and Mill, Climax Molybdenum Company (CMC), Climax, CO

   Facility Overview: The site was initially mined from 1914 to 1919. Mining and milling of
   molybdenum resumed from 1967 until 1974 when the ore body was exhausted. The mine
   had been inactive since then. CMC had revegetated roads and reservoir dam faces with
   fill from the upper and lower tailings drainage areas.  Tailing ponds and reservoirs
   overflowed seasonally.
Waste Stream(s): The inactive mine had three NPDES discharge points: Outfall 001, the
discharge from the lower Urad reservoir; Outfall 002, the combined point discharge of all
drainage from the upper tailings area;  and Outfall 003, the combined point discharge of all "   '
drainage from the lower tailings area.

Waste Management Practices: Upon closure, waste rock from the Henderson mine, another
CMC facility nearby, was used to reclaim the tailings areas, followed by application of sewage
sludge and wood chips, and revegetation.  Both the upper and lower tailings areas were
equipped with drainage systems to direct infiltration to the creek. The systems were not
connected and did not capture all of the drainage from the tailings areas.  Discharge from the
upper tailings area flowed to Ruby Creek and to the lower tailings area, where treated
wastewater from the Henderson mine enters, and flows ultimately to West Fork Clear Creek.

Type of Impact/Media Affected:  The discharge from the tailings areas and the mine portal,
which were located in and near Woods Creek had caused the water quality standards in Woods
Creek to be exceeded. Arsenic, cadmium, copper, iron, lead, manganese, silver, nickel,  zinc,
and hexavalent chromium had consistently been detected in the Henderson Mine discharge,
which flowed into lower Urad reservoir, the tailings areas, underdrain discharges, and Outfall
001.  Levels of manganese, zinc, and cadmium in Outfall 001 had exceeded applicable water
quality standards.  Several of these contaminants had been detected in Woods Creek below
each of the tailings areas.

Regulatory Action/Response: The discharges mentioned above had caused state limits for
many water quality parameters to be exceeded. As a result, the site was listed under Section
304(1) of the Clean Water Act (CWA) as significantly contributing to impairment of water quality
in Woods and West Fork Clear Creeks. In response,  the state issued Urad a permit that was
intended to fulfill the requirements under Section 304(1). EPA, however, determined that the
state permit did not satisfy these requirements and, therefore, disapproved the proposed permit
in lieu of a federal permit. The federal NPDES permit issued for URAD in June 1991 served as
the "individual control strategy" (ICS) to address the impacts on  Woods and Clear Creek. The
permit required that Urad meet final effluent limits based on applicable water quality standards
and comply with all toxicity limits at Outfalls 002 and 003.

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Colorado
Comments were received on this damage summary. See Appendix A for comment listing and
Agency response.

References:  U.S. EPA. Draft.  Mining Waste Releases and Environmental Effects Summary
for the State of Colorado. March 1994.

Cyprus Amax. Comments to Phase IV Proposed Rule on Land Disposal Restriction to Mineral
Processing Wastes.  1996.

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                                                                         Florida
                          Bartow Chemical Plant:
        Radioisotopes Contaminate Florida Ground Water
   Sector: Phosphoric acid

   Facility: Bartow Chemical Plant, Seminole Fertilizer Corporation (formerly W.R. Grace &
   Company), Bartow, Polk County, FL

   Facility Overview: Production facilities of the site included phosphoric and sulfuric acid
   plants, ammoniated phosphate plants, a triple super phosphate plant, and a phosphate
   rock grinding facility.
Waste Stream(s): Phosphogypsum and process wastewater.

Waste Management Practices: The Bartow Chemical Plant is underlain with three aquifers.
The depth of the surficial aquifer ranges from 10 to 60 feet.  The intermediate aquifer ranges in
depth from 59 to 200 feet. The typical depth at the facility to the uppermost useable aquifer
(the Floridan) is approximately 200 feet.

      Waste management facilities at Seminole included one wastewater treatment plant, nine
surface impoundments, two landfills, and two phosphogypsum stacks. The wastewater
treatment plant, which was a two-stage liming facility, was used only during unusually intense
rainfall events. Two surface impoundments were associated with the wastewater treatment
plant: Surface Impoundment No. 1 was the primary liming pond and Surface Impoundment
No. 2 was the secondary pond. Surface Impoundment No. 3 occupies approximately 1.3 million
square feet and was used as a cooling pond for process wastewaters, while Surface
Impoundments Nos. 4-6 were a series of interconnected cooling ponds. The pH of the process
water in the cooling ponds varied from 1.8 to 2.3, due to seasonal rains.  Surface
Impoundments Nos. 7-9 were old clay settling ponds.  Of the facility's two landfills, only one
was in use as of 1990.  Landfill No. 1, occupying approximately 28 acres, was closed.  Landfill
No. 2 occupied2 acres and was used for filter cloths and solid materials not pumped to the
gypsum stacks

      The north gypsum stack, which first received waste in 1954, occupied approximately
159 acres at an average height of 28 feet. This stack received process wastewater,
phosphogypsum, gypsum solids from "tank clean out," and filter cloths. As of December 31,
1988, the north gypsum stack contained 14 million short tons of material. The south gypsum
stack, which first received waste in 1965, occupied approximately 66 acres at an average
height of 46 feet.  As of December 31, 1988, the south gypsum stack had accumulated
42 million short tons of material.

Type of Impact/Media Affected:  Activities at the Seminole Fertilizer Corporation facility had
resulted in elevated levels of several parameters in ground water in the surficial and

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Florida
intermediate aquifers.  This contamination had affected potable water wells in the area, some of
which had been replaced with water from the City of Bartow's public supply.

       Seminole maintained eight monitoring wells as part of the ground water monitoring
system required for its state permit. Seminole  had stated that MW-3 and MW-7 were
upgradient, background wells.  All other wells were listed as downgradient.  The facility's ground
water data from September 1986 through March 1989 showed that the downgradient wells
repeatedly exceeded the water quality standards for pH, gross alpha radiation, radium-226,
radium-228, iron, manganese,  TDS, sulfate, cadmium, chromium, lead, and fluoride.

Regulatory Action/Response: On March 8, 1988, the Florida DER issued a warning notice to
W.R. Grace & Company for violations of its ground water monitoring permit during the third and
fourth quarters of 1987. The standards for gross alpha radiation, radium-226 and radium-228,
and sodium had been exceeded in some ground water samples.  The analytical results showed
the following maximum concentrations for each parameter: gross alpha, 107 pCi/L; radium-226
and -228, 14.4 pCi/L; and, sodium, 657 mg/L

       In addition to on-site wells, neighboring potable water wells had also been adversely
affected.  Analytical data from May 1988 showed that 12  of 18 wells contained at least one
contaminant at levels above the drinking water standards. Contaminants found in the samptes'
included arsenic, lead, sodium, gross  alpha, radium-226, radium-228, iron, pH, sulfate, and total
dissolved solids.  Potable water wells  near the facility were replaced by a public water supply
from the City of Bartow; W.R. Grace apparently paid for the water supply line installation and
connection to the affected water users.

       Seminole had also received a warning notice from the Florida DER in 1984 for an
unpermitted discharge of process water from the facility to Bear Branch.

No comments were received on this comment summary.

References: U.S. EPA. Report to Congress on Special Wastes from Mineral Processing
Facilities.  Volume II: Methods and Analyses.  July 1990.

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                                                                         Florida
                East Tampa Chemical Plant Complex:
                      Acidic  Discharge Kills  Crabs
   Sector: Phosphoric acid

   Facility: East Tampa Chemical Plant Complex, Gardinier, Inc., East Tampa,
   Hillsborough County, FL

   Facility Overview: Production and treatment facilities at the site included phosphoric
   and contact acid plants, a dry products manufacturing unit, wet rock mills, and a double
   lined treatment unit.
Waste Stream(s): Phosphogypsum and process wastewater.

Waste Management Practices: Gardinier, Inc.'s East Tampa Chemical Plant Complex
encompassed about 2,600 acres located at the mouth of the Mafia River adjacent to
Hillsborough Bay. The plant began operating in 1924 and had been expanded several times by
various owners.  In 1973, Gardinier, Inc. took over the entire operation.  Operations included
production of phosphoric acid and phosphate and other fertilizers.

      Gardiner's on-site waste management units included two process water ponds (Nos. 1
and 2) and a gypsum stack.  Process Water Pond No. 1 was an unlined pond that occupied
32 acres and was 6 feet deep; Process Pond No. 2 occupied 32 acres and was 8 feet deep.
The gypsum stack, which as of December 31, 1988, contained about 76 million cubic yards of
material, occupied an area of 61 acres and was 200 feet high.  The ponds on top of the gypsum
stack occupied 6.5 acres and were 7 feet deep.  The typical pH of the liquid in the gypsum
stack ponds was 1.8, which was highly acidic.

      Phosphogypsum was piped to the gypsum stack as a slurry mixture with approximately
30 percent soHds. The gypsum settled from the slurry and the liquid was decanted for reuse in
the manufacturing process. Water that seeped through the stack was collected in a perimeter
drain which was buried at the toe of the stack. The drain carried the seepage water to a sump
in the northeast comer of the gypsum stack, where it was pumped to an evaporation pond
located on part of the gypsum stack. Surface water run-off from the exterior slopes of the stack
was discharged into Hillsborough Bay.

Type of Impact/Media Affected: Records at the Hillsborough County Environmental
Protection Commission (HCEPC) cited environmental incidents at the Gardinier facility as far
back as November 21, 1973, when HCEPC investigated a citizen's complaint and discovered
210 dead crabs in traps placed near the facility's northwest outfall. The pH of the outfall water
was 2.9.

Regulatory Action/Response: Water quality violations attributable to Gardinier resulted in the
following administrative actions as of 1989: <1) a Consent Order negotiated between the

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Florida
HCEPC and Gardinier on August 22, 1977; (2) a Citation to Cease Violation and Order to
Correct from HCPEC on November 8, 1984; (3) a Warning Notice-from the State of Florida
Department of Environmental Regulation (FDER) on April 9, 1987; (4) a Citation to Cease and
Notice to Correct Violation from the HCEPC on May 26, 1988; and (5) a Warning Notice from
FDER on October 18, 1988. These administrative actions were issued to Gardinier following
unpermitted discharges from either the gypsum stack or the cooling water ponds.

       HCEPC issued the November 8, 1984, citation for an untreated effluent-discharge which
occurred on October 8,  1984. The citation noted that "toe-drain effluent contains several
thousand mg/L of fluorides and phosphorus and up to 150 pCi/L of radioactive substances.
Also, its pH can be as low as 1.5 standard units." A sample of the discharge on March 30,
1987, which resulted in the April 9, 1987, warning notice, showed that the pH was 1.9, total
phosphorus was 6,740 mg/L, and  dissolved fluorides was 4,375 mg/L. HCEPC subsequently
analyzed another sample of the discharge which resulted in the October 18, 1988, warning
notice and reported the following results:  pH, 2.2; total phosphorus, greater than 4,418 mg/L;
and fluoride, 1,690 mg/L.

       The May 26,  1988, citation from HCEPC states that "available agency records indicate a
considerable history of incidents of discharge resulting in exceedances of environmental
standards and contamination of the air and waters of  Hillsborough County. Enforcement in - •
each case required remedial actions intended to correct the effects of the discharge where
appropriate, as well as design and maintenance measures to prevent reoccurrence of the same
or like incident.  Despite all efforts, such incidents continue to occur."

       HCEPC records  also included a Gardinier Air Complaints Summary which lists 78 citizen
complaints about the facility from December 6, 1983,  to May 10, 1988. The complaints were
made about noxious odors, fumes, smoke, dust or mist from the facility.  One of the complaints
clearly identified the gypsum stack as the source; the relationship of the other complaints to
gypsum and water management systems at the facility could not be determined from the
available documentation. HCEPC responded to most of these complaints with a phone call or
site visit.  At least three of the site visits resulted in HCEPC issuing a warning notice to the
facility.

       Since 1985, Gardinier had  monitored ambient  air quality  for radon and fluoride. In 1985,
Gardinier reported its average radon-222 flux from the gypsum pile to be 21.6 pCi/m2-sec. (The
NESHAP specifies a limit of 20 pCi/m2-sec). Ambient fluoride was 0.43 ug/L, with a maximum
reading of 1.2 MQA--  Gardinier reported that no National Ambient Air Quality Standards or
National Emissions Standards for  Hazardous Air Pollutants were exceeded during 1988.

       In addition to the impacts to surface water, biota, and air noted above, the facility
operations had contaminated ground water.  Ground water quality had been monitored
quarterly at the facility for several years.  Since January 1, 1984, standards for the following
drinking water parameters were exceeded in wells located both upgradient and downgradient of
the facility's special waste management units: chromium, radium-226 and radium-228, gross
alpha, chloride, iron, manganese,  pH, and total dissolved solids. Examination of data for the
period 1987 through early 1989 indicated that several on-site wells in  the shallow aquifer
routinely exceeded the gross alpha primary drinking water standard by a factor of between 2
and 4; exceedances in the intermediate aquifer were also common, although less frequent and
of lesser magnitude.

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                                                                       Florida
No comments were received on this comment summary.
References: U.S. EPA. Report to Congress on Special Wastes from Mineral Processing
Facilities.  Volume II: Methods and Analyses. July 1990.
                                     Pase fil

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Florida
                      Plant City Chemical Complex:
              Ground Water Contaminated at CPI Plant
   Sector:  Phosphoric acid

   Facility: Plant City Chemical Complex, Central Phosphates, Inc. (CPI), Plant City,
   Hillsborough County, FL

   Facility Overview: The production facilities at the CPI complex included two phosphoric
   acid plants, four sulfuric acid plants, a uranium extraction plant, one wet rock grinding
   unit, four granulation plants, and two storage and shipping units.
Waste Stream(s): Process wastewater and phosphogypsum.

Waste Management Practices:  The Central Phosphates, Inc. (CPI) Plant City Chemical
Complex occupied approximately 1,520 acres of land. The site is underlain by a surficial
aquifer and the Floridan aquifer. The surficial  aquifer ranges in depth from 1 to 50 feet and was
recharged by local rainfall. In the Floridan aquifer, the uppermost useable aquifer at the site,
wells were generally cased to depths greater than 200 feet.  The principal uses of the water in
the uppermost useable aquifers underlying the site were rural domestic, agricultural, and
commercial/industrial.

      The CPI plant began producing phosphate fertilizer, sulfuric acid, ammonia, and other
products in 1965. Phosphogypsum generated during the production of phosphoric acid was
disposed on-site at a 410-acre phosphogypsum stack. A 20 acre unlined process water cooling
pond completely surrounded the gypsum stack. The cooling pond was 8 feet deep.  As of
December 31, 1988, the unlined gypsum stack was 111 feet high and contained approximately
70 million tons of material. The top of the gypsum stack contained eight ponding areas
occupying a total area of approximately 43 acres. Two designated areas on top of the stack,
located in the middle, were used for disposal of non-hazardous waste materials, such as
construction and demolition debris and non-hazardous chemicals.

Type of Impact/Media Affected: Activities at the Central Phosphates site had contaminated
the surficial and upper Floridan aquifers. The  surficial aquifer and, to an undetermined extent,
the Floridan aquifer had increased levels of fluoride, sodium, gross alpha radiation, heavy
metals, sulfate, total dissolved solids, and nutrient compounds in excess of applicable guidance
concentrations and/or state and federal drinking water standards. Contaminated ground water,
primarily in the surficial aquifer, had migrated off-site under approximately 27.5 acres of the
Cone Ranch property, located south of the CPI facility, as of 1989.

Regulatory Action/Response:  Quarterly ground water sampling began at the Central
Phosphates facility in April 1985.  Based on the results of sampling from these wells in the
second quarter of 1985, the Florida Department of Environmental Regulation (DER) issued a
warning notice to the facility for violating the primary drinking water regulations. Maximum

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                                                                           Florida
contamination levels for sodium and chromium were exceeded in a downgradient well in the
Floridan aquifer and for sodium, chromium, and fluoride in a downgradient well in the surficial
aquifer.

       The final report on ground water investigations conducted at Cone Ranch during May
and June 1987 identified two areas of contamination on the Cone Ranch property:

             Contamination in one area (designated Area A) was caused by a dike
             failure and resultant spill of process water from the Central Phosphates
             facility in 1969; and

       •      Contamination in another area (Area B) was caused by seepage of
             contaminated water from the recirculation pond located immediately north
             of the spill area.

       DER and Central  Phosphates, Inc. signed a Consent Order addressing the ground
water contamination problems at the site on September 29, 1987.  The Consent Order
documented violations of primary and secondary drinking water standards for chromium,
sodium, fluoride, gross alpha radiation, lead, and cadmium from a downgradient well in the
surficial aquifer. These violations occurred from May 6, 1985, through April 27, 1987; maximurh
values listed in the consent order for each contaminant were as follows: chromium, 0.075
mg/L; sodium, 1,700 mg/L; fluoride, 6 mg/L; gross alpha, 29 pCi/L; lead, 0.11 mg/L; and,
cadmium, 0.022 mg/L. The Consent Order required CPI to implement corrective measures and
ground water remediation at the site..

       The Joint Water Quality/RCRA Overview Committee of the Florida Phosphate Council
had recorded quarterly sampling data from CPI from April 24, 1985, through January 18, 1989,
for DER Well Nos. 1 through 6, as well as data from sampling in April 1988 for miscellaneous
other wells located both on and off CPI property. These data showed consistent exceedances
of water quality standards in the downgradient surficial aquifer for pH, iron, fluoride,
manganese, total dissolved solids, and sulfate. Water quality standards for iron and total
dissolved solids were consistently exceeded in the downgradient upper Floridan aquifer.

       The Contamination Assessment Report for the CPI facility,  prepared pursuant to the
Consent Order, concurred with the assessment made by the West Coast Regional Water
Quality Authority in its definition  of two plumes of contaminated ground water which had
migrated off-site. Area A was found to comprise an area of 15.5 acres in the surficial aquifer
and 1 acre in the upper Floridan aquifer. The off-site areal plume within the surficial aquifer
was found to extend approximately 500 feet south  and 1,500 feet east of the CPI property.  The
plume in the surftciat aquifer of Area B was found to extend approximately 490 feet south in the
Cone Ranch property, covering an area of approximately 2 acres.

No comments were received on this comment summary.

References: U.S. EPA.  Report to Congress on Special Wastes from Mineral Processing
Facilities. Volume II: Methods and Analyses. July 1990.
                                       Page

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Idaho
                              Blackbird Mine:
              Endangered Salmon Potentially Affected
                          by Poor Water Quality
  Sector: Copper

  Facility:  Blackbird Mine, Noranda Mining Company, Lemhi, ID

  Facility Overview: Since the late 1800's, various companies have mined for cobalt and
  copper by shaft and open pit methods. The current owner, Noranda Mining Company,
  has not operated the mine since 1982.
Waste Stream(s): Waste piles.

Waste Management Practices: Mining tunnels and waste rock piles were scattered along
eight miles of Meadow and Blackbird Creeks.  The piles and the open pit mine were located at
the headwaters of Bucktail Creek. Some waste piles were as large as two million cubic yards.

Type of Impact/Media Affected: Acid drainage from the tunnels and leaching from waste piles
contributed to poor quality streams in the area. Many investigations have documented the poor
water quality and negative impacts on aquatic life of creeks downstream of the mine. Recent
sampling documented high levels of arsenic, copper, cobalt, and nickel in downstream surface
water and sediments. Copper levels exceeded EPA's Fresh Water Ambient Water Quality
Criteria. The Snake  River Sockeye Salmon, designated by the U.S. Fish and Wildlife Service
as an endangered species, and the Snake River Spring/Summer Chinook Salmon, designated
as a threatened species have been potentially affected by poor water quality.

Regulatory Action/Response:  The site was added to the NPL in 1993.

No comments were received on this comment summary.

References: U.S. EPA.  Draft. Mining Sites on the NPL.  August 1995.

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Idaho

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Idaho
                     Bunker Hill:  One of the Largest
                      and Most Complex  NPL Sites
  Sectors: Cadmium, lead, silver, zinc,
  phosphate, and sulfuric acid

  Facility:  Bunker Hill Mining and
  Metallurgical Complex, Gulf Resources,
  Kellogg, Shosone County, ID

  Facility Overview: Mining began in
  1889; smelting started in  1917.  The
  facility includes the Bunker Hill mine, a
  mill and concentrator, a lead smelter, an
  electrolytic zinc plant, a phosphoric acid
  and fertilizer plant, a cadmium plant,
  sulfuric acid plants, and a central
  treatment plant. Plant operation ceased
  around 1980.
                                             Waste Stream(s): Slag and tailings.

                                             Waste Management Practices: Initially, all
                                             liquid and solid residues from mining and
                                             milling operations were discharged into the
                                             South Fork River and its tributaries. The
                                             river flooded periodically and deposited
                                             mining waste material or tailings onto the
                                             valley floor.

                                                   In the 1920s, waste management
                                             consisted of discharging mill tailings to a
                                             small impoundment, and placing lead smelter
                                             slag in a pile. Later, after reprocessing the
                                             tailings in the first impoundment, the resulting
                                             tailings were deposited in the Central
                                             Impoundment Area (CIA). After 1961, the
                                             coarse fraction of mill tailings served as sand
                                             backfill in the Bunker Hill Mine.  The CIA also
                                             received mine drainage beginning in 1965,
gypsum from the phosphoric acid and fertilizer plant after 1970,  and wastes from the zinc plant
and smelter after 1974.  Decant from the CIA flowed directly into the river until 1974, after which
time the decant from the gypsum discharge was returned to the phosphate plant.

Type of Impact/Media Affected:  The Bunker Hill Superfund Site has been one of the largest
and most complex Superfund sites in the nation.  The site is three miles wide and seven miles
long. Contaminants of concern have included antimony, arsenic, beryllium, cadmium, cobalt,
copper, mercury, selenium, silver, zinc, asbestos, and polychlorinated biphenyls.

       The upper 10 to 20 feet of soils on the valley floor have been combined with mine and
mill tailings and rock dust generated in the early part of the century.  Early milling practices
resulted in the deposition of metals-rich tailings to low-lying areas. The South Fork of the Coeur
d'Alene River received mine and mill waste for approximately 90 years. Surface water
contaminant sources have included direct discharge of acid mine drainage, direct discharge of
lead smelter and zinc plant wastes, seepage from impoundments, numerous accidental spills,
and overland flow contaminated by heavy metals.  Primary sources of ground water
contamination have included seepage from the CIA, infiltration and ground water flow through
valley-wide deposits of tailings, and ground water inflow upgradient of the site.

       In 1986, EPA removed contaminated soils from 16 parks, playgrounds, and road
shoulders. In 1989 and  1990, contaminated soil was removed from residential yards; yards
chosen for the program had lead levels of greater than 1,000 ppm and were residences of small
children or expectant mothers.

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                                                                            Idaho
Regulatory Action/Response:  In 1968, the construction of tailings ponds was mandated, and
in 1974, wastewater treatment of outflow from tailings ponds was required.  Bunker Hill was
listed on the NPL in September 1983.  Through a health intervention program, EPA has
recommended against eating locally grown vegetables due to their possible contamination.  In
1989, an inspection of the smelter complex conducted by the Agency for Toxic Substance and
Disease Registry (ATSDR) resulted in a Public Health Advisory that concluded that the smelter
complex was a significant risk due to acute exposure to arsenic from the copper flue dust piles,
acute exposure to lead, cadmium, arsenic, and asbestos, chronic exposure to lead, cadmium,
arsenic, and asbestos during site operations such as salvaging, and physical hazards.  ATSDR
recommended that site access be restricted.

A/o comments were received on this comment summary.

References:
U.S. EPA.  Draft Final. Mining Sites on the National Priorities List: NPL Site Summary Reports.
Volume!. June 21, 1991.

Ceto, Nick (EPA Region 10). Written Correspondence Concerning Bunker Hill to Bruce
Rappaport, ICF Incorporated. December 4, 1995.

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Idaho
         Lucky Friday Mine:  Tailings Discharge Kills Fish
                            and Aquatic Insects
  Sectors: Gold, silver, lead, and zinc

  Facility: Lucky Friday Mine, Hecla Mining Company, Mullan, ID

  Facility Overview: The Lucky Friday Mine and Mill had been in continuous operation
  since June of 1987. The site consisted of a 1,000 standard-ton-per-day flotation mill
  operating on-site and an underground mine.
Waste Stream(s): Mill tailings.

Waste Management Practices: Tailings sofution was piped to tailings ponds.  Hecla was
permitted to discharge this solution to the Coeur D'Alene River under certain conditions.    "  '

Type of Impact/Media Affected: A January 28, 1988, release caused tailings to be released
to the South Fork of the Coeur D'Alene River. Water samples taken 0.4 miles downstream
detected 628 mg/L of total suspended solids. Another rupture released tailings to the South
Fork.  In September 1988, 100 gallons of copper sulfate were accidentally dumped into the
South Fork, causing fish and aquatic insect kills.  The Idaho Department of Environmental
Protection (IDEP) estimated that it would be at least seven years before the fishery regained its
pre-spill population.

Regulatory Action/Response:  IDEP filed an NOV on May 15, 1990, for the September 6,
1988, copper sulfate spill. The NOV cited violations for failing to contain hazardous material,
not ensuring that every effort was made to prevent the spill, and failure to notify the state
immediately after the spill occurred. The violations carried fines of up to $10,000 per violation
and $1,000 per day per continuing violation. Hecla was required to arrange a compliance
meeting with IDEP in which they outlined the steps taken to correct the circumstances that
resulted in the copper sulfate spill.

No commenfavwre received on this comment summary.

References: U.S. EPA.  Draft. Mining Waste Releases and Environmental Effects Summary
for the State of Idaho. March 1994.

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Idaho

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Idaho
                              Microgold II Mine:
              Mercury Contamination from Gold Mining
   Sector: Gold

   Facility: Microgold II Mine, Powell Mining and Micro Gold II Partnership, Florence, ID

   Facility Overview: The Microgold II Mine was composed of three claims on unpatented
   land in the Nez Perce National Forest. Mining operations occurred only during the
   summer of 1983. Ore was crushed and passed over a series of shaker tables. Mercury
   was then added to form an amalgam, which was heated. Gold was recovered, and
   mercury was recondensed from vapor.
Waste Stream(s): Tailings.

Waste Management Practices: Tailings from shaker tables were discharged to an unlined
tailings pond.

Type of Impact/Media Affected: Releases of mercury contaminated the soils in the immediate
vicinity of the processing area and around the shaker table mixing area.  Approximately 12
pounds of mercury were released to soils in the shaker table area,  contaminating approximately
20,000 square feet of soil.  The tailings pond was contaminated with mercury by the discharge
of untreated tailings.  It was not determined whether elevated levels of mercury detected in
ground water were due to the tailings seepage or a naturally contaminated spring in the area.

Regulatory Action/Response:  The Idaho Department of Health and Welfare (IDHW) issued
an NOV to Micro Gold II on November 23, 1983, because of the mercury levels in the tailings
pond. A Finding and Order, dated February 14, 1984, found that the Micro Gold facility had
operated without federal or state permits to discharge water and had used unlined settling and
tailings ponds that provided an unimpeded route for possible ground water contamination. The
Idaho Board of Health and Welfare (IBHW) ordered the mine's operators, Powell Mining, to
prevent  mercury migration, and to conduct monitoring and sampling.  An Administrative
Complaint was filed on September 10, 1984, alleging that Powell Mining did not comply with the
Order. In February 1985, IDHW issued an Administrative Order requiring Micro Gold to develop
a site investigation and cleanup plan. Cleanup using on-site encapsulation began in the spring
of 1986. Under a Stipulation, Agreement, and Consent Decree issued on August 29, 1986,
Powell placed money into an  escrow account to pay for the remediation. This action absolved
Powell of any further liability related to the mercury contamination.

No comments were received  on this comment summary.

References: U.S. EPA. Draft. Mining Waste Releases and Environmental Effects Summary
for the State of Idaho.  March 1994.
                                       Paee 70

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                             Idaho
Page 71

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Idaho
                                Nu-West Plant:
                   Wastewater Spill Flows Four Miles
  Sector:  Phosphoric acid

  Facility: Nu-West Plant, Nu-West Industries-Conda, Soda Springs, ID

  Facility Overview: The Nu-West site was a large, complex facility that included
  processing equipment acquired over approximately 10 years.
Waste Stream(s): Phosphogypsum and process wastewater.

Waste Management Practices: The Nu-West plant covered approximately 1,600 acres. With
the exception of a period from 1985 to 1987, the plant had been in operation since 1964.  Nu-
West formulates and markets phosphate-based chemicals and fertilizers. The phosphogypsurrt
waste was a by-product of the digester system, which produces ortho-phosphoric acid (P2O5)
from phosphate ore. Gypsum was slurried with process water and pumped to two storage
ponds on top of the gypsum stacks, which had been used since 1964 and covered
approximately 600 to 700 acres as of 1990. The gypsum ponds were unlined; the stacks were
about 150 feet above the  natural ground surface. Drainage systems decanted slurry water from
the top of the higher ponds into lower ponds.

Type of Impact/Media Affected: During March 1976, a dike surrounding the Nu-West cooling
pond failed and released 400 acre feet of wastewater into the surrounding area.  The water
spread out and ponded on an estimated 50 to 100 acres of farm land. The water then migrated
via a natural drainage  path, forming a small river that extended four miles to the south.
Wastewater reportedly infiltrated into local soil and underlying bedrock along its overland
migration path, but never  entered a natural surface water body.

      While the Idaho Division of Environment determined that dilution during spring run-off
reduced surface concentrations of contaminants to within acceptable limits,  the Caribou County
Health Department recorded significant increases in  ground water concentrations of phosphate,
cadmium, and fluoride immediately following the spill. Samples from a J.R.  Simplot Company
(Conda Operation) production well  No. 10, located downgradient from the Nu-West facility,
showed that before the spill occurred, ground water phosphate levels averaged 100 mg/L, and
after the spill, rose to 1,458 mg/L.  Levels of cadmium in the ground water averaged 0.01 mg/L
before the spill and 0.239 mg/L after the spill, and levels of fluoride averaged 5 mg/L before,
and 39 mg/L after, the spill.

Regulatory Action/Response:  In 1987, EPA Region 10 conducted a file review and site
inspection of Nu-West. This inspection  included ground water sampling, aqueous and solid
sampling from the waste ponds, and a geophysical survey.  Six ground water samples were
collected: two from on-site industrial production wells (MF well, P.W. No. 1); two from off-site
industrial production wells (Simplot No.  11, Simplot No. 10); and two from domestic wells in the

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                                                                             Idaho
site area. Selenium exceeded federal Primary Drinking Water Standards in all of the production
well samples. Manganese and sulfate exceeded Federal Secondary Drinking Water Standards
in Simplot Well No. 10.  Phosphate was detected at 8.2 mg/L in Simplot Well No. 10, a level
approximately 30 times greater than that found in the MF well and 170 times greater than that
found in the background well (Simplot Well No. 11).  A total of 11 target compound list inorganic
elements were detected in at least one of the domestic well samples; however, none of the
sample concentrations exceeded Federal Primary or Secondary Drinking Water Standards.

      The geophysical survey results indicated that there was  no significant difference
between the background and on-site values obtained from the survey.  The EPA Site Inspection
Report, however, stated that "Levels of TCL inorganic elements and anions detected in the
ground water samples during the [EPA]  site investigation were similar to those obtained by the
Caribou County Health Department during non-spill event time periods. The levels, however,
detected during the [EPA] site investigation should not be considered indicative of stable long-
term ground water quality conditions at the site ....  [Data showed] that significant increases in
ground water contaminant concentrations have occurred as a result of a past spill at the Nu-
West facility. Although survey results were inconclusive, the data suggest that some leakage
from the cooling pond may be occurring presently. If leakage from the cooling pond increases
as a result of pond aging or increased water circulation, a contaminant plume may develop and
migrate to the south-southwest." Seven registered domestic wells within a three mile radius, of.
the Nu-West site served an estimated 27 people.  These wells ranged  between 90 feet and 245
feet deep. Eleven registered industrial production wells existed on and near the Nu-West site,
one of which provided drinking water for approximately 45 J.R. Simplot employees in Conda
(Simplot #11).

No comments were received on this comment summary.

References:  U.S. EPA. Report to Congress on Special Wastes from  Mineral Processing
Facilities.  Volume II:  Methods and Analyses. July 1990.
                                        Page 73

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Illinois
             Illinois Zinc Plant:  Heavy Metals  Released
                         by  Run-off and Leachate
   Sector: Zinc

   Facility: Zinc Corporation of America (ZCA), DePue, IL

   Facility Overview: From 1905 until 1966, New Jersey Zinc operated a zinc smelter,
   sulfuric acid plant, phosphoric acid plant, and diammonium phosphate plant at this facility.
   In 1966, Mobil Chemical Company purchased all plants except the zinc smelter, which
   ZCA operated until 1971. In 1990, there were approximately 26 employees producing
   zinc dust from zinc scrap.
Waste Stream(s): Zinc slag.

Waste Management Practices: Zinc smelting wastes were deposited in one pile at the
southern end of the site. The pile covered approximatefy 10 acres and ranged up to 50 feet
high.  In addition, several smaller piles on the site measured approximately 100 feet in length
and 10 to 12 feet in height. These smaller piles may have contained zinc slag in addition to
other materials.

Type of Impact/Media Affected: As early as 1967, the predecessor agency to the Illinois
Environmental Protection Agency (EPA), the Illinois Sanitary Water Board, suspected rainfall
run-off contamination from zinc slag piles located on New Jersey Zinc's property. The Illinois
EPA monitored the surface run-off and leachate from the zinc slag pile from 1973 to 1986.
These analyses consistently showed levels of zinc, cadmium, copper, manganese, and lead in
excess of the maximum contaminant levels (MCLs) for drinking water. For example, from
March 5, 1973, to March 26, 1986, run-off samples that exceeded the established MCLs for
drinking water from the slag pile ranged from  39 - 4000 mg/L for zinc (MCL = 5.0 mg/L); 0.5 -
3.6 mg/L for lead (MCL = .05 mg/L); 2.32 - 780 mg/L for manganese (MCL = 0.05 mg/L); 1.38 -
137.5 for copper (MCL = 1.3); and, 0.58 -19.3 mg/L for cadmium (MCL = 0.01 mg/L).  Run-off
control measures (e.g., capping) helped to reduce the levels of contaminant discharge. Surface
water samples taken during April, May, and June of 1989,  after remedial controls were
implemented at the facility, showed the following range of concentration levels:  zinc, 44.0 -
75.2 mg/L; lead, 0.05 - 0.06 mg/L; manganese, 1.8 - 3.83 mg/L; copper, 3.2 - 4.4 mg/L; and
cadmium, 0.18- .79 mg/L.

Regulatory Action/Response:  Due to repeated problems in meeting effluent standards from
this site, Zinc Corporation of America received a five-month discharge variance in April 1988,
and a five-year extension to this variance in January 1989.  Discharge monitoring reports
submitted by the facility for the fourth quarter  of 1989 indicated that few surface water
contamination problems remained.  Monitoring data on the quality of ground water beneath the
slag piles were not available.
                                       Paae 74

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                                                                        Illinois
No comments were received on this comment summary.
References: U.S. EPA. Report to Congress on Special Wastes from Mineral Processing
Facilities. Volume II:  Methods and Analyses. July 1990.
                                     Page 75

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Illinois

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                                                    Kansas and Oklahoma
                                  Tar Creek:
         Mine Water Contaminates Drinking Water Source
   Sectors: Lead and zinc

   Facility:  Tar Creek, Ottawa County, OK and Cherokee County, KS

   Facility Overview:  Lead and zinc were mined at the site from 1904 to the mid-1960's.
   After mining operations ceased, the mines were flooded by inflows of surface and ground
   water.
Waste Stream(s): Acid mine drainage.

Waste Management Practices:  Large capacity pumps were used during active mining to
control ground water inflow and flooding. When mining activities ceased in the mid-1960s, the-
pumps were removed from the mines. By 1979, the majority of the underground mines were
completely flooded. Acid mine drainage began to discharge via abandoned or partially plugged
mine shaft openings and boreholes.

Type of Impact/Media Affected: High concentrations of metals in the surface and ground
water were caused by sulfur-bearing minerals in the mine workings.  At locations both above
and below the acid mine water discharge points, chronic water quality criteria for several heavy
metals were exceeded.  Heavy metal loadings increased downstream, while the pH decreased,
resulting in severe stress to the aquatic community of Tar Creek.  Studies found no fish and
only a few benthic macroinvertebrates were surviving in Tar Creek. The Creek was used for
recreational purposes, including swimming. Several communities in Ottawa County had
experienced ground water quality problems related to the mines. The contamination had been
attributed to mine water entering the wells as a result of inadequate casings.

Regulatory Action/Response:  In 1979, the Oklahoma Water Resources Board and the U.S.
Geological Survey first investigated the site. Tar Creek was added to the NPL list in October
1981. Remediation was completed in 1986, and EPA continued to monitor the site.

Comments were received on this damage case. See Appendix A for comment listing and
Agency response*

References:  U.S. EPA. Draft Final. Mining Sites on the National Priorities List: NPL Site
Summary Reports. Volume IV. June 21,1991.

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Kansas and Oklahoma

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                                                                       Louisiana
                 Allied-Signal Hydrofluoric Acid Plant:
         Untreated Wastewater Discharged to Mississippi
   Sector: Hydrofluoric acid

   Facility: Allied-Signal, Geismar, LA

   Facility Overview: The facility produced hydrofluoric acid by combining fluorospar rock
   with sulfuric acid in a furnace.
Waste Stream(s): Fluorogypsum and process wastewater.

Waste Management Practices:  Fluorogypsum generated from the production of hydrofluoric
acid was slurried with process water as it was removed from the furnace.  The resulting slurry
was transferred through a conduit system to an impoundment on the top of a fluorogypsum"
stack.  Seepage and run-off from the fluorogypsum stack was collected in clay-lined ditches and
flowed into an impoundment referred to as the clean/veil. Some water from the clearwell was
recycled into various plant operations, while excess water was discharged as needed into the
Mississippi River via a NPDES permitted outfall after passing through a wastewater treatment
plant.

       Within the time period from 1986 to 1987, in an effort to find a profitable use for the
large quantities of gypsum waste accumulating at Allied Signal's facility, Louisiana Synthetic
Aggregates, Inc. (LASYNAG) began marketing the gypsum as a road base material. The
gypsum was reportedly processed by excavating and screening the material from the
fluorogypsum stockpile located at the Allied-Signal hydrofluoric acid plant in Geismar,
Louisiana. Once processed, the fluorogypsum was marketed and shipped as "Florolite."

       To avoid excessive levels of water in the clearwell during periods of high rainfall, which
could lead to catastrophic failure of the containing levee, Allied had occasionally bypassed the
treatment facility and discharged the clearwell water directly into the Mississippi River.  This
situation was allowed by EPA and Louisiana Department of Environmental Quality (LADEQ)
under proper emergency circumstances (e.g., prior notice, reasonable cause).  Emergency
discharges occurred in January 1983; and from August 1983  through October 1983. In April
1984, Allied notified EPA of its intention to again bypass the treatment facility when discharging
its clearwell water if its level rose another 12 inches, to a depth of 30 feet.

Type of Impact/Media Affected: Discharges or spills of untreated wastewater had caused
contamination on several occasions. In April 1978, Allied noted a seepage area northwest of
the clearwell; subsequent sampling  revealed a low pH and the presence of phosphate in the
seepage. In July 1978, a gypsum line break reduced pH levels in a drainage ditch feeding into
Bayou Breaux. Allied discovered another leak in October 1980 in the northeast corner of the
clearweU. Consultants to Allied noted that contaminated water penetrating the clay surfacing
was "resulting in vegetation kills which cannot be tolerated." In August 1981, a gypsum slurry

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Louisiana
transport line ruptured and a portion of the Bayou Breaux dropped in pH from around 7 to as
low as 2.6.

       One of the primary difficulties in managing the gypsum stack and clean/veil areas was
preventing their physical failure. Stack failures had occurred in the past.  In May 1979, Allied's
east gypsum stack failed, resulting in the overflow of low pH gypsum slurry water into a
roadside ditch along Highway 30. An estimated 95 percent of the spilled water was recovered.
In October 1980, consultants to Allied Chemical identified four interrelated clean/veil and
gypsum stack problems: (1) levee overtopping; (2) levee stability (high risk of stack failure); (3)
levee crest subsidence; and (4) levee toe leak.  In August 1983, another slide (failure) occurred
on Allied's gypsum stack.

       In 1987, LASYNAG had the milled fluorogypsum used as road constructions material
analyzed by  several laboratories. One laboratory reported that with a resistivity of 500 ohms-
cm and a pH of 5.2, the material was considered very corrosive for most iron and steel
products.  The laboratory also stated that the high sulfate content and the low pH would likely
make the material corrosive to concrete as well.

Regulatory Action/Response: During 1987, after several rounds of requests and data
submittals, Louisiana's Department of Transportation and LADEQ's Office of Solid and
Hazardous Waste authorized the use of Florolite on various road shoulders, embankments, and
base courses.  At least some of these approved projects were completed, including road work
at a mobile home park.

      In July 1988, the City of New Orleans Department of Streefs concluded that the material
would be acidic and corrosive for iron, steel,  and concrete products and deemed the use of
Florolite as a road base material in the City inadvisable.

      On June 7, 1989, LASYNAG began construction of a test embankment for the "U.S.
Highway 90 relocation construction project" through a stretch  of wetlands in southern Louisiana
near Amelia. After three weeks, LADEQ responded to complaints of dying biota and found
"extremely acidic pH and high conductivity in water adjacent to the roadbed."  Construction was
ceased immediately.

No comments were received on this comment summary.

References:
U.S. EPA. Report to Congress on Special' Wastes from Mineral Processing Facilities. Volume
II: Methods and Analyses.  July 1990.

U.S. EPA. Report to Congress on Special. Wastes from Mineral Processing. Technical
Background  Document: Damage Case Investigation. July  1990.

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                                                                      Louisiana
   Arcadian Phosphoric Acid Plant:  Emergency Discharges
                of Wastewater Released to Mississippi
   Sector: Phosphoric acid

   Facility: Arcadian, Geismar, LA

   Facility Overview: This facility, formerly owned by Allied Chemical, had been
   operational since 1967.
Waste
Stream(
s):
Phospho
gypsum
and
process
wastewa
ter.
Waste Management Practices: Approximately 150 residents lived within one mile of the
facility, which was situated along the Mississippi River. There were private drinking water wells
within a one-mile radius of the facility.  The water table occurs at 80 feet below the lahd surface
in the wet season, and 100 feet in the dry season. The Mississippi River receives the
discharges from this facility.                                                       -  '

       The phosphogypsum waste was slurried to the stack with process wastewater, which
drained into a retention pond referred to as "the clearwell." There were four clearwells of
differing sizes at the site, one of which was described as active. Six phosphogypsum stacks
occupied the site as well, one or two of which appear to be active.

       The effluent guidelines prohibiting discharge of process pollutants from a wet phosphoric
acid facility were rescinded for the plants on the lower Mississippi due to poor soil stability and
excess precipitation. EPA Region 6 described the condition as follows: "The withdrawal of the
guidelines allowed the creation of the concept of active and inactive impoundments.  The
inactive impoundment drainage may be discharged directly to the receiving stream without
limits provided no further wastes were sent to the inactive  system and the discharge meets
water quality standards."

Type of Impact/Media Affected: Two major categories of contaminant releases had occurred
at this facility:  radioactivity releases to the ground water and clearwell discharges to surface
water causing excessive phosphorus and fluoride loadings, as well as elevated pH.  A third area
of concern was fluoride fugitive emissions from the clearwell.

       Arcadian had installed numerous monitoring wells throughout the gypsum stack and
clearwell areas.  Arcadian's ground water monitoring report for the second half of 1988 showed
gross alpha radiation in well P4 at 95 ± 31 pCi/L and 60 ±14 pCi/L in well P10.  The MCL for
gross alpha radiation was 15 pCi/L.  These releases were  not extensively documented in the
files reviewed for the 1990 Report to Congress; the documents reviewed did not discuss actions
taken in response to the results presented.

       High precipitation in this region had prompted Arcadian to perform emergency
discharges of excess water from its clearwell. Arcadian had justified this action by stating that
until the NPDES permit effluent limitations were modified, there were no other environmentally

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Louisiana
acceptable alternatives to the emergency bypass of the clearwell water.  Excess water
apparently may have caused failure of the gypsum stack or of the clean/veil walls.  During a
discharge on February 27, 1987, Arcadian stated that the action was necessary "to prevent
possible injury and severe property damage." Such a discharge occurred again beginning on
March 10 of the same year.  During these discharges, pH values ranged from 1.3 to 2.5;
phosphorus concentrations from 3,688 mg/L to 7,960 mg/L; and fluorine concentrations from
6,188 to 14,649 mg/L

Regulatory Action/Response: An EPA NPDES Violation Summary, based on discharge
monitoring reports from March  1986 to December 1987, showed that Outfall 003 violated
effluent limits each month from at least December 1985 until August 1987. Contaminant
concentrations were similar to those listed above. No enforcement action was taken for any of
these violations, apparently because of the absence of an enforceable permit.

      On December 8, 1988, EPA Region 6 issued an Administrative Order to Arcadian
regarding several violations, including the discharge on October 28 of that year of calcium
sulfate run-off (Outfall 003) containing total phosphorus of 8,176 Ibs/day, exceeding the
permitted limit of 7,685 Ibs/day.

No comments were received on this comment summary.

References: U.S. EPA. Report to Congress on Special Wastes from Mineral Processing
Facilities. Volume II: Methods and Analyses. July 1990.

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                                                                     Louisiana
              Faustina Works  Phosphoric Acid Facility:
            Low pH Water Released to St. James Bayou
   Sector: Phosphoric acid

   Facility: Agrico Chemical Company, Donaldsonville, LA

   Facility Overview: AGRICO Chemical Company's Faustina Works phosphoric acid plant
   began operations in 1974. In 1990, approximately 68 residents inhabited land within one
   mile of the facility.
Waste Stream(s): Phosphogypsum and process wastewater.

Waste Management Practices: Gypsum waste was slurried with process wastewater to a
stacking area, where the solids settled out, and the water drained into adjacent ponds or   '  '
clean/veils. These wastes had caused problems with elevated concentrations of phosphorus
and fluoride and acid pH levels in surface and ground waters. Emergency discharges of
untreated waters to surface water had occurred periodically throughout much of the 1980s;
contamination of the ground water was reported in 1986.  Receiving waters were the
Mississippi River and the St. James Bayou.

Type of Impact/Media Affected:  On April 15, 1983, a portion of Agrico's 62-foot gypsum stack
failed structurally and released 60 million gallons of water from its 100-acre pond onto plant
property. The spilled water was pumped to another gypsum holding stack. Concern over the
potential failure of this stack, however, led Agrico to discharge the untreated  water to the
Mississippi River over  a period of several weeks. These discharges exceeded permit limits.
After the pond failure, water of pH 2 was found flowing in an on-site drainage ditch at
approximately 20 gallons per minute into the St.  James Bayou.

      The large volume of released water had destroyed a dam that controlled flow from the
drainage ditch into the St. James Canal. Agrico  reinstalled the dam on April  22, 1983, and
transferred the low pH water still in the dammed section of the ditch back to the gypsum pond
system.  Agrico checked the water in  St. James Canal,  concluding that it did  not seem affected
by the low pH water discharged to it as a consequence of the April 15,1983, gypsum pond
failure.

      Due to heavy rainfall, Agrico had continued to periodically perform emergency
discharges of untreated stormwater from the clearwell, as occurred in March and again in June
1987. In its letter of notification, Agrico stated that "additional rain could result in catastrophic
levee failure leading to loss of life, personal injury, or severe property damage."

      In March 1986, Agrico reported to LA DEQ that the water along the length of the north
and east phosphogypsum perimeter ditches might have been "slightly impacted" by phosphate,
sulfate, and fluoride.

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Louisiana
       In August 1986, Agrico submitted to LA DEQ a Hydrologic Assessment report for the
facility. LA DEQ regarded the reported situation as requiring corrective action, stating that
"Contamination of the shallow ground water, although by constituents which were not of great
concern, poses a threat to drinking water."

Regulatory Action/Response:  Even under non-emergency circumstances, Agrico had
difficulty keeping in compliance with NPDES permit limitations. In April 1987, an investigator
reported that discharges from Agrico's inactive gypsum impoundment (Outfall 002) permitted
levels by up to 35-fold.

       In August 1987, LA DEQ  determined that Agrico could not comply with the Louisiana
Water Discharge Permit System  that had been effective since March 1987.  LA DEQ issued an
Administrative Order to Agrico to allow the facility to temporarily discharge water from gypsum
stacks until standards were met.

No comments were received on  this comment summary.

References:  U.S. EPA. Report to Congress on Special Wastes from Mineral Processing
Facilities. Volume II: Methods and Analyses.  July 1990.
                                       Page 84

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                                                                    Louisiana
                         Ormet Aluminum Plant:
           Red Mud Discharges Cause High pH in Canal
  Sector: Alumina (bauxite)

  Facility:  Ormet Corporation, Burnside, LA

  Facility Overview:  An alumina processing facility which produced only about 1 percent
  of the total reported 1988 alumina production.
Waste Stream(s): Red muds.

Waste Management Practices:  Ormet Corporation's aluminum plant was situated near the
Mississippi River. The processing unit generating red muds had been operational since 1958.
The facility contained four red mud lakes, referred to as Nos. 1, 2, 3, and 4. These        -  '
impoundments had a combined surface area of 210 acres. Impoundments Nos. 1 and 2 had
been inactive since 1984. Impoundment 4 was the most recently constructed pit.

Type of Impact/Media Affected: During heavy rainfall events when excess water had
accumulated in closed red mud impoundments 1 and 2, Ormet had discharged to a tributary of
the "Panama Canal" on an emergency basis. The Panama Canal flows from east to west along
the northern boundary of the facility, through residential areas, and was a source of domestic
water in some cases.

      Discharge of excess waters had resulted in high pH levels in some cases. For
example, excess water was discharged to the Panama Canal between May 23 and May 27,
1983. Due to improper operation of the neutralization station, combined with communications
problems, high pH levels were not detected until after the discharge event.  The excessive pH
levels ranged from 9.4 to 10.2 for 4.5 hours on May 23, 1983, and from 9.7 to 9.8 for 7.5 hours
on May 24, 1983.

      Ormet had stated that "the Panama Canal cannot readily assimilate the discharge of
excess rainwater from the Red Mud Impoundments" and that "flow in the Panama Canal stops
on some occasions, and on others actually flows backward because of wind or tidal  action."
The Louisiana Department of Environmental Quality (LADEQ) raised concern over the impact of
these discharges on the Panama Canal, and requested that Ormet look into the option of
discharging to the Mississippi River. The emergency discharges to the Panama Canal had
imparted a red color to the canal water, resulting in complaints from local residents.
Investigation into this phenomenon led LADEQ to conclude that the problem was primarily
aesthetic, and no formal action was taken.  LADEQ, however, did contact Ormet about
"ameliorating the conditions in the Panama Canal."

Regulatory Action/Response: In 1987, LADEQ's Ground Water Protection Division
expressed concern that Ormet's proposal to close the red mud impoundments in their present
                                      Page 85

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Louisiana
condition would allow production of leachate and possible ground water contamination. LADEQ
also suggested continued ground water monitoring as a part of closure. Ground water
monitoring data were not found in the documents reviewed for the 1990 Report to Congress.

No comments were received on this comment summary.

References: U.S. EPA. Report to Congress on Special Wastes from Mineral Processing
Facilities.  Volume II: Methods and Analyses.  July 1990.
                                       Page 86

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                                                                       Michigan
      Torch Lake Copper Mines: Tailings Contaminate Fish
                   and Create Public Health Concern
   Sector: Copper

   Facility: Torch Lake, Keweenaw Peninsula, Houghton County, Ml

   Facility Overview: From 1868 to 1916, copper ore was milled and processed around
   Torch Lake.  From 1916 to 1968, copper recovery from previously discarded tailings in
   Torch Lake steadily increased using a flotation process that agitated ore, water, oil, and
   chemical reagents.
Waste Stream(s): Tailings and process wastewater.

Waste Management Practices: Beginning in the 1860s, mills crushed, ground, and drove-  •
copper through successively smaller meshes. Copper and crushed materials were separated
by gravity in a liquid medium. After sending the recovered copper to a smelter, the tailings and
process wastewaters were disposed of into or on the land surrounding Torch Lake. In 1916,
copper recovery from previously discarded tailings began. The submerged tailings were
collected, screened, recrushed, and gravity-separated at one of three reclamation plants.
Initially, copper was recovered using an ammonia-leaching process.  Later, the procedure
consisted of a flotation process that agitated ore,  water, oil, and chemical reagents, and created
a froth that would support copper-bearing particles. After the process, the tailings were
discharged into Torch Lake. The last mill closed in 1968. In the 1970s, copper recovery plants
again began operating, but discharged only noncontact cooling water to Torch Lake.

Type of Impact/Media Affected:  Between 1868 and 1968, Torch Lake received an estimated
200 million tons of tailings, reducing the Lake's volume by 20 percent and dramatically altering
the shoreline.  In 1989, the U.S. Bureau of Mines sampled mine-tailings leachate and water
quality and concluded that leachate from Torch Lake mine tailings was extremely low in
comparison to leachate from 30 other sites and that the tailings released very little metal.
Studies, however, had found an increased incidence of lesions and tumors on Sauger and
Walleye caught in Torch Lake.

Regulatory Action/Response: In 1983, the Michigan Department of Public Health issued a
fish consumption advisory on all Sauger and Walleye caught in Torch Lake. Also in 1983, the
International Joint Commission's Water Quality Board designated Torch Lake as a Great Lakes
Area of Concern.  In June 1988, EPA listed Torch Lake as an NPL site. In 1988, the
Preliminary Health Assessment for Torch Lake conducted by the Agency for Toxic Substances
and Disease Registry concluded that the site was a potential public health concern because of
possible exposure to unknown etiological agents that may have created adverse health effects
over time.

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Michigan
Comments were received on this damage summary. See Appendix A for comment listing and
Agency response.

References: U.S. EPA. Draft Final. Mining Sites on the National Priorities List: A/PL Site
Summary Reports.  Volume V. June 21, 1991.

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                                                                        Missouri
                          Doe Run Lead Smelter:
                  Slag  Metals Found  in Ground Water
   Sector: Lead

   Facility: Doe Run, Boss, MO

   Facility Overview: Also known as AMAX Homestake Smelter, the facility produced a
   black semi-glassy, sand-sited slag during the reduction of lead sinter by coke. The facility
   began operating in 1968.
Waste Stream(s): Lead slag.

Waste Management Practices: The 250-acre site was located on a ridge separating the  -   .
watersheds of the Left Fork of Neals Creek (to the south) from that of Crooked Creek (to the
north.) This area had been identified as a recharge area for the underlying aquifer.  There were
private drinking water wells within a one-mile radius of the facility.  The water table occurred at
145 feet below the land surface in both the wet and dry seasons. A perched water table also
existed five feet below the land surface. Crooked Creek received wastewater discharges from
smelting operations, while Strother Creek received discharges from the mine and mill.  The
mean annual precipitation was about 46 inches.

      The slag disposal area consisted of a flat-topped "bench" along the eastern side of the
head of a small valley that was underlain by clay-based  residuum. The slag was piped as a
slurry to the slag disposal area where it was dewatered, then trucked to the on-site sinter plant
for reuse as sinter or to the slag disposal area for disposal. A total of about 480,000 tons of
slag had been placed in the slag disposal area over nearly 20 years of primary smelter
operation.  The piled slag covered about 5 acres at its base with a thickness of 20 to 55 feet.
The slag pile was generally unvegetated.

Type of Impact/Media Affected: Doe Run  began a comprehensive investigation of the
primary smelter slag disposal area  in 1984.  Soil boring analyses revealed that some residuum
samples from-beneath the slag contained elevated concentrations of lead, zinc, and cadmium.
The exhibit below shows analyses of boring  samples typical for uncontaminated residuum,
contaminated residuum, and the slag itself.  These data show that uncontaminated residuum
might have contained up to 10 mg/kg lead. The slag itself may have contained 3,800 mg/kg,
while the residuum contaminated from slag leachate may have contained 2,400 mg/kg lead.
Similar comparisons could  be made for zinc and cadmium, and possibly copper.

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Missouri
                       Metals Content of Slag and Residuum
                             Doe Run, Boss, Missouri
Sample
K1
K2
K9
K10
K9
Media
Uncontaminated
Residuum
Uncontaminated
Residuum
Contaminated
Residuum
Contaminated
Residuum
Slag Pile
Depth (ft.)
16-16.5
54 - 54.5
43.5-44
21 -22
24-24.5
Concentration (mg/kg)
Pb
5.4
10
2,400
990
3,800
Zn
16
27
390
230
6,800
Cd
0.11
0.13
7.3
2.8
14
Cu
37
41
160
28
250
      Monitoring well data from 1988 showed that cadmium, lead, and zinc concentrations in
the ground water below the slag disposal area exceeded drinking water-standards. These data
showed that contamination of the ground water below the slag disposal area had occurred,
though it was unclear if this contamination was attributable to the slag pile directly or to two
adjacent impoundments that contained water from the slag storage area.  Several independent
laboratories analyzed subsamples of each sample to derive a mean value. Mean cadmium
levels ranged up to 0.67 mg/L (67 times the MCL); lead ranged up to 0.6 mg/L (12 times the
MCL); and one mean value for zinc contained 7.4 mg/L (1.5 times the MCL). Three wells had
consistently elevated cadmium levels:  the 11 samples from well K2 averaged 0.087 mg/L; the
six samples from well K5A averaged 0.431  mg/L; and the six samples from well K8 averaged
0.021 mg/L. These wells were all located within 400 feet of the slag disposal area, and all
appeared to be downgradient. Background monitoring well data were not located in the
available documentation for the 1990 Report to Congress.

Regulatory Action/Response:  In 1984, EPA Region 7 performed a Potential Hazardous
Waste Site Preliminary Assessment. The inspector found that "surface impoundments and stag
piles containing heavy metals could  possibly contaminate ground and surface water."  The
inspector also listed blowing dust from the slag pile under "Hazardous Conditions and
Incidents."

No comments were received on this comment summary.
References: U.S. EPA. Report to Congress on Special Wastes from Mineral Processing
Facilities.  Volume II: Methods and Analyses.  July 1990.

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                                                                       Missouri
                           Glover Lead Smelter:
            Contamination in Ground and Surface Water
   Sector: Lead

   Facility: ASARCO, Glover, Iron County, MO

   Facility Overview: This primary lead processing facility began operations in 1968.  It is
   located within the Mark Twain National Forest in the Missouri Ozarks, in an area known
   as the "Old Lead Belt." (According to ASARCO, the facility is located in an area known as
   the "New Lead Belt," and is not located in within the Mark Twain National Forest)
Waste Stream(s): Lead smelter slag.

Waste Management Practices: Slag generated by the smelter was stored in an on-site pile
which was upslope and upgradient of the facility.  Wastewater discharged under an NPDES
permit, surface run-off and ground water flow from the facility towards or into Big Creek.
Although in preparing the 1990 Report to Congress, EPA found no documentation directly
stating that the lead slag piles were the source of heavy metals releases to surface or ground
waters, some of the data reviewed suggest that the lead slag was at least part of the source.

Type of Impact/Media Affected:  In May 1985, ASARCO conducted a hydrologic
characterization of the Glover facility.  Data from this study showed that, in contrast to
background or upgradient samples, elevated cadmium, zinc, manganese, and possibly
chromium concentrations were present in many surface and ground water samples collected
downgradient of the lead slag pile. (See exhibits below.) Cadmium concentrations exceeded
the MCL by a significant amount in bedrock wells (0.027 - 0.053 mg/L), shallow wells (0.52 - 2.3
mg/L), and surface waters (0.52 - 4.3  mg/L) downgradient of the slag.  Manganese and zinc
were also present in the shallow wells and surface water downgradient from the slag pile.
Background values for the deep aquifer were not available.

      In October 1985, the Missouri  Department of Natural Resources (MODNR) stated,
based on the data reviewed up to that time, that "[ejither there was a very significant nonpoint
source of cadmium or there were significant unreported discharges from ASARCO or there
were both."

Regulatory Action/Response: In May 1987, EPA conducted a Potential Hazardous Waste
Site Investigation and expressed concern that "surface water run-off from slag piles could be
contaminating the streams surrounding the lead smelter with heavy metals." In 1988, under a
Settlement Agreement with the MODNR, ASARCO constructed a collection and treatment
system for stormwater run-off from the facility, including the slag area.  Asarco reports that in
1994, it entered into a Consent Decree with MODNR, which requires a site assessment and
investigation to determine the nature and extent of certain contamination at the site.  According
to Asarco, the Site Assessment has not yet been completed.  Asarco points out that it will not

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Missouri
be possible to determine whether slag is the source of contamination until the Site Assessment
has been completed.

Comments were received on this damage summary. See Appendix A for comment listing and
Agency response.

References: U.S. EPA. Report to Congress on Special Wastes from Mineral Processing
Facilities. Volume II: Methods and Analyses.  July 1990.

ASARCO. Comments to Phase IV Proposed Rule on Land Disposal Restriction to Mineral
Processing Wastes.  1996.

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                                                                                    Missouri
        Summary of Exceedances from Well and Surface Water Analyses
                                ASARCO, Glover, Missouri


Station*"
Deep Aquifer
Downgradient
103D
Shallow Aquifer
Upgradient
101
102
Downgradient
MW-4
103
104
105
MW-3
Surface Water
Scroggins Branch
300
301
Slag Seep
303

Total No.
Samples"1


3


6
6

6
3
6
6
6


5
6

6
Number of Samples Exceeding MCL/Maximum Exceedance Factor0
Cd



2/5.3


0
0

6/230
3/4.5
6/57
0
3/1.7


0
1/1.2

6/430
Fe



0


0
0

1/2.1
0
6/6.8
0
0


0
0

0
Mn



0


0
0

5/2.4
0
6/9.9
4/2.3
0


a
0

1/1.26
Pb



2/1.4


1/1.4
0

3/2.4
0
1/1.6
1/1.6
3/1.6


0
1/1.6

6/5.6
Zn



0


0
0

2/1.86
0
0
0
0


0
0

5/7.14
TDS

•

3/4.04


0
0

6/4.01
3/1 88
5/2.29
0
0


0
0

6/2.65
SO,



3/4.52


0
0

6/4.76
3/1 82
3/2.41
0
0

-
0
0

6/3.28
(a)      Bedrock Well = 1030 (Depth to gw=12.3m; distance from slag pite<50m).
        Shallow Wells = MW-4 (depth<2m; distanced 00m); MW-3 (depth<3m; distanced 00m); 104 (depth=1m;
        distanced 00m); and 105 (depth=1.7m; distance<200m); Background (referenced by ASARCO) = 101
        (depth=0.76m; distance=244m); and 102 (depth=1,2m; distance=732m).
        Surface Water Station = 303 (Slag Pite Seep); Background - Scroggins Branch (referenced by ASARCO) = 300
        (distance from slag pite=244m) and 301 (distanced 52m).
(b)      Samples collected between 8/84 and 3/86.
©       First value was number of samples exceeding MCL. Second value is Maximum Exceedance Factor, which was
        derived by dividing highest concentration detected by the MCL (e.g., a concentration of 0.12 mg/L lead exceeds the
        MCL of 0.05 mg/L by a factor of 2.4).

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Missouri

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                                                                     Missouri
                    Oronogo-Duenweg Mining Beit:
                Contaminants Spread Over Wide Area
  Sectors: Lead and zinc

  Facility:  Oronogo-Duenweg Mining Belt, Jasper County, MO

  Facility Overview: Mining began in the area around 1848 and continued until the late
  1960's. As many as 4,000 shallow subsurface mines and some strip mines were worked
  in the area until 1970 when all commercial mining had ceased.  The site is located in the
  tri-state mining district of Kansas, Missouri, and Oklahoma.
Waste Stream(s):  Tailings, barren rock, and other process wastes.

Waste Management Practices: Tailings were skimmed from the jigging table and discarded in
large piles. Waste products from processing were placed in large tailings piles. Barren rock
containing no valuable minerals was also discarded in piles.

Type of Impact/Media Affected: Contaminants from the site spread over a wide area by
surface water flow, ground water migration, and atmospheric dispersion.  Contaminated media
at the site have included ground water, surface water, sediment, surface soil, and certain
components of the aquatic and terrestrial food chain.  Contaminants of concern included
cadmium, lead, and zinc.

Regulatory Action/Response:  The U.S. Department of Health and Human Services and the
Agency for Toxic Substances and Disease Registry (ATSDR) completed a Preliminary Health
Assessment for the site. In addition, the State of Kansas conducted several health surveys that
indicated a high incidence of tuberculosis and lung cancer among area residents.

No comments were received on this comment summary.

References: U.S. EPA. Draft Final.  Mining Sites on the National Priorities List: NPL Site
Summary Reports.  Volume IV. June 21,1991.

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Missouri

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                                                                      Montana
     Anaconda Smelter:  Pollution from Copper Processing
               Wastes Force a Community to Relocate
  Sector: Copper

  Facility:  Anaconda Smelter, Mill Creek, MT

  Facility Overview:  The Anaconda Copper Mining Company began smelting operations
  in 1884. In 1977, the company merged with ARCO. From 1977 to 1980, ARCO operated
  the smelter. All structures were demolished in 1980, except the stack.  The Anaconda
  smelter was one of four separate but contiguous Superfund sites located in the Clark Fork
  River Basin.
Waste Stream(s): Tailings, furnace slag, and flue dust.                              _  .

Waste Management Practices:  Ore processing wastes including about 185 million cubic
yards of tailings, 27 million cubic yards of furnace slags, and 250,000 cubic yards of flue dust
were contained within an area of more than 6,000 acres. These wastes contained elevated
concentrations of copper, cadmium, arsenic, lead, and zinc. Tailings were usually deposited in
ponds to allow solids to settle out before recycling or releasing the wastewater into nearby
waterways.  Tailings mounds up to 90 feet deep remained on-site.

Type of Impact/Media Affected: Soil sampling in the Mill Creek community showed much
higher levels of arsenic and other heavy metal contaminants than other communities in the
area.  Arsenic was concentrated in the top six inches of soil.  In the majority of soil profiles
sampled, arsenic concentrations approached area background levels at a depth of 42 inches.
May 1986 water samples indicated arsenic contamination in seven household water supplies.
Urine samples from pre-school children living in Mill Creek, conducted by the Center for
Disease Control in 1985, found greater arsenic exposure than in children from another
community in the Anaconda area. Mean urinary arsenic levels of residents living in Mill Creek
residents decreased after they were permanently relocated under the Superfund program.

Regulatory Action/Response: The Anaconda Smelter site was listed on the NPL in
September 1983.  In July 1986, EPA entered into an Administrative Consent Order with ARCO
to conduct an expedited remedial investigation and feasibility study for Mill Creek.  The Record
of Decision, completed in 1987, mandated the permanent relocation of Mill Creek residents.
This remedy was selected in part because the area had the potential to become
recontaminated.

No comments were received on this comment summary.

References: U.S. EPA.  Mining Sites on the National Priorities List: NPL Site Summary
Reports, Volume I. 1991.

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Montana

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                                                                       Montana
                             Basin Creek Mine:
                Gold Mine Contaminates Local Waters
  Sector: Gold

  Facility: Basin Creek Mine, Basin Creek Mining, Inc. (subsidiary of Pegasus Gold),
  Lewis and Clark and Jefferson Counties, MT

  Facility Overview: Basin Creek Mine was an open pit gold mine that conducted cyanide
  heap leaching. Basin Creek Mining acquired the mine, formerly owned by Pangea
  Mining, in 1989.
Waste Stream(s): Spent leaching solution.

Waste Management Practices: Cyanide heap leaches had leaked three times.  The first leak
resulted from a valve that was left open causing an unspecified amount of cyanide to leak onto
a leach pad dike.  Cyanide solution flowed through a hole at the top of the liner resulting in the
percolation of cyanide through the course fill under the leach pad. The second cyanide leak
was caused by a Bobcat loader which tracked material from lined to unlined areas. Cyanide
was also found in a sediment pond used to collect run-off drainage from process areas.

Type of Impact/Media Affected: A 1990 Environmental Assessment identified two streams
with lower pH and higher sulfate, iron, manganese, and zinc concentrations than other streams
in the  area. These two streams occasionally exceeded EPA drinking water standards and
aquatic life criteria. The cyanide leaks mentioned above had resulted in Basin Creek Mining
removing contaminated surface soils to lined areas.  Ground water monitoring had shown
elevated fluoride levels downgradient of leach pad #3 near or above the federal Drinking Water
Standards. Other wells downgradient of leach pad #1 and the  general facilities area showed
elevated manganese and iron levels that exceeded federal Drinking Water Standards. Water
quality information from springs in the Monitor Creek drainage  showed conditions typical of acid
mine drainage (i.e., low pH and high metals).  Two springs showed lead and cadmium levels
exceeding federal Drinking Water Standards; one of these springs also contained low
concentrations of cyanide.

Regulatory Action/Response: The Montana Department of State Lands issued a Notice of
Noncompliance (No. 135) for cyanide contamination in a mud puddle near the agglomeration/
pugmill area.  No other regulatory actions were described in the available information,

No comments were received on this comment summary.

References: U.S. EPA.  Draft.  Mining Waste Releases and Environmental Effects Summary
for the State of Montana.  March 1994.

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Montana

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                                                                       Montana
                            Cable Creek Project:
         Spring Thaw Causes Overflow Pond Discharges
   Sectors: Gold and other precious metals

   Facility: Cable Creek Project, Cable Mountain Mine, Inc., Deer Lodge County, MT

   Facility Overview: Cable Mountain Mine obtained gold ore by excavating gold-bearing
   sands and gravels in placer deposits within and adjacent to Cable Creek. Ore was
   washed, the gold concentrate was ground, and mercury mixed in. Gold was removed
   from the mixture using amalgam plates.
Waste Stream(s): Waste rock and mercury bearing solution.

Waste Management Practices:  Overburden and coarse tails were stockpiled on-site and were
backfilled into the mined-out pit. Tailings were treated to remove any mercury remaining in
them before they were used as backfill.  Fine tails were held in settling ponds ahead of the pit,
and removed as overburden as the pit progressed. A sediment control basin had been
constructed at the downgradient end of the mine site to remove sediment from the creek before
it left the site.

Type of Impact/Media Affected:  In the spring of 1989, the settling ponds rapidly filled as a
result of the spring thaw. Cable Mountain Mine was forced to discharge from the sediment
control pond directly to surface water by circumventing the final settling pond.

Regulatory Action/Response:  As a result of the surface water release, the Montana
Department of State Lands recommended in a Notice of Nonconformance that Cable Mountain
Mine cease discharges, submit a plan for removal of deposited sediment, and submit a revised
operating plan, in compliance with Montana's Water Quality Act, which addresses the spring
thaw problem. On May 22, 1989, the Montana Department of State Lands issued a Notice of
Noncompliance (NON) to Cable Mountain Mine for violation of the Montana Metal Mine
Reclamation Act (MCA Sections 82-4-301):  Unauthorized discharge from sediment pond
(Notice of civil penalty related to NON 125). As part of this notice, on January 14, 1991, Cable
Mountain Mine was assessed a civil penalty of $700 for the violation.

No comments were received on this comment summary.

References: U.S. EPA. Draft. Mining Waste Releases and Environmental Effects Summary
for the State of Montana. March 1994.

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Montana
                          Page 102

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                                                                        Montana
                            East Helena Smelter:
             Elevated  Blood-Lead Levels Found Nearby
  Sectors: Lead and zinc

  Facility: East Helena Smelter, ASARCO, East Helena, Lewis and Clark County, MT

  Facility Overview: The site included an active primary lead smelter with an adjacent
  paint pigment plant.  Former practices at the site included recovery of lead bullion and
  zinc from the smelter's waste slag (1927-1982).  The smelter began operations in 1888.
Waste Stream(s): Process wastewaters.

Waste Management Practices:  Four major process fluid ponds had been used for (1) the
collection and storage of water used in the main plant process circuit; (2) cooling hot speiss-  '
during speiss granulation processing; (3) recirculating into the scrubber and sinter plant; and
(4) preliminary settling of suspended solids.  Three ponds were still in operation. The fourth
pond was previously used for preliminary settling of suspended solids from main plant
operations.  This unit contains no process fluids and was no longer in operation.

Type of Impact/Media Affected: Contamination from this plant had been measured over a
100-square mile area. The sources of contamination were primary and fugitive emissions and
seepage from process ponds and process fluid circuitry.  Blood tests in children residing in the
adjacent community had shown levels twice the national average.  Asarco claims that the blood
lead testing of children in the community was conducted due to air emissions, and that process
waters have not contributed to any health-related problems, particularly not to elevated blood
lead levels.  The studies mentioned below found contaminated soils in residential areas and the
Endangerment Assessment showed contamination in pond sediments, on-site soils, surface
water, and ground water below the site and the town of East Helena.  Seepage from one of the
ponds into Prickly Pear Creek contributed to ongoing violations of state water quality standards,
principally caused by mining leachate entering the creek upstream of the smelter. Constituents
of primary environmental concern included arsenic, cadmium, copper, lead, and zinc. Arsenic
was of the greatest concern due to its mobility and carcinogenicity.

Regulatory Action/Response:  Numerous environmental investigations had been conducted
at the site since 1969. The Montana State Air Quality Bureau (AQB) and the United State
Geological Survey (USGS) had monitored and studied the site, and the Center for Disease
Control (CDC) had tested blood-lead levels of residents.  The site was added to the NPL in
September 1983. Remedial Investigation/Feasibility Studies had been prepared for the four
operable units at the site. The Endangerment Assessment prepared in support of the
Feasibility Study for the process ponds identified a human health risk.  In the process of
negotiations between EPA and the PRPs, a consent decree was signed on June 30, 1990, in
support  of the Record of Decision (ROD) on the operable unit containing the process ponds.

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Montana
According to Asarco, implementation of the ROD is having a positive impact on groundwater
quality.

Comments were received to this damage summary.  See Appendix A for comment listing and
Agency response.
References: U.S. EPA.  Draft Final. Mining Sites on the National Priorities List:  A/PL Site
Summary Reports.  Volume II. June 21, 1991.

ASARCO. Comments to Phase IV Proposed Rule on Land Disposal Restriction to Mineral
Processing Wastes.  1996.
                                     Pa ere

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                                                                        Montana
                            U.S.  Antimony Mine:
           Mine Tailings Contaminate Creek and Wildlife
   Sector: Antimony

   Facility: U.S. Antimony Corporation (USAC), Thompson Falls, Sanders County, MT

   Facility Overview: From 1972 to 1983, the facility beneficiated antimony concentrates
   by leaching the ore in a solution of sodium hydrosulfide and caustic soda. From 1984
   until 1987, plant operations were ceased due to environmental violations. In 1987, the
   plant reopened with a different beneficiation operation.
Waste Stream: Spent barren solution.

Waste Management Practices:  Barren solution was regenerated and recycled before being
discharged to one of three tailing ponds. Due to poor current efficiency in the electrowinning
circuit, as well as precautions against the potential generation of stibine gas (a deadly poison),
high solution concentrations (6,000 -10,000 mg/L) of antimony were deposited in the flotation
mill tailings ponds. The tailing ponds were located on U.S. Forest Service land under a Forest
Service special use permit. While most of the antimony and arsenic were precipitated as stable
sulfides, soluble antimony concentrations of 10 -150 mg/L remained in the  tailings. The facility
closed in 1984 and reopened in 1987 under a NPDES permit, which stipulated a new method
for processing antimony and handling process wastes. This method precipitated any soluble
arsenic or fugitive antimony as environmentally stable sulfides.

Type  of Impact/Media Affected: Tailing pond water containing soluble antimony and arsenic
leached into the underlying aquifer, which recharged Prospect Creek.  The  U.S. Forest Service
inspected the site in 1984 and discovered that the tailings piles were accessible to game
animals, especially elk and deer, due to damage to the wildlife fence surrounding the effected
area.  The Forest Service determined elk, deer, and other animals, attracted by mineral salts in
the tailings, were ingesting antimony and arsenic, thus exposing humans and other predators to
contamination.  The Forest Service inspection also revealed windblown tailings being deposited
beyond the permitted tailings disposal area.

Regulatory Action/Response: The Montana Department of Health and Environmental
Services issued an NOV and Corrective Action Order in December 1984 to  address the
contamination of the underlying aquifer and Prospect Creek.  The  Department  ordered USAC to
halt all activities and to submit a Study Plan including ground water and surface water
monitoring and proposals for any necessary corrective action. USAC had met  all the NOV
requirements and, as noted above, the facility re-opened in 1987.

No comments were received on this comment summary.

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Montana
Bibliography: U.S. EPA. Draft.  Mining Waste Releases and Environmental Effects Summary
for the State of Montana. March 1994.

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Montana

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Nevada
                           Nevada Moly Project:
     Mercury Spilled Down Water Well at Molybdenum Mine
  Sectors: Molybdenum mine (with copper as a co-product)

  Facility: Nevada Moly Project, Cyprus Tonopah Mining, Tonopah, NV

  Facility Overview:  The site consisted of an open pit mine and a flotation mill with an on-
  site tailings impoundment.
Waste Stream(s): Tailings.

Waste Management Practices:  Tailings were discharged from the mill to two 400-foot
diameter thickeners, and the resulting slurry was piped to the on-site tailings impoundment.
Tailings reclaim solution was recycled into the process water system.

Type of Impact/Media Affected:  In May 1989, accidental drainage of a sodium hydrosulfide
storage tank resulted in the release of process solution beyond the mill building's containment.
The spill occurred near the copper concentrate storage area; consequently, much of the
material was absorbed by the copper concentrate.  Escaping solution followed the contours of
the area downslope to the tailings impoundment sump.

      In March 1990, a mercury spill occurred from a broken submersible pump seal. Mercury
splashed on top of the flange, onto the surrounding top soil, and down the well.  Approximately
5.783  kg of mercury was lost, and of that approximately 5.354 kg went down the well.

Regulatory Action/Response: On March 29, 1990, the Nevada Division of Environmental
Protection (NVDEP) issued a Finding of Alleged Violation to Cyprus Tonopah Mining as a result
of the  spill of mercury into one of the on-site wells,  NVDEP found that Cyprus allegedly violated
NRS 445.221 by discharging a pollutant without a permit.  Cyprus was ordered to cease
pumping of the affected well, perform a video survey of the well, and submit a remediation plan.
Cyprus' remediation plan was accepted. On December 11, 1991, NVDEP approved Cyprus'
request to reconnect the remediated well to the site's water system.

Comments were received to this damage summary. See Appendix A for comment listing and
Agency response.

References: U.S. EPA.  Draft.  Mining Waste Releases and Environmental Effects Summary
for the State of Nevada.  March 1994.

Cyprus. Comments to Phase IV Proposed Rule on Land Disposal Restriction to Mineral
Processing Wastes. 1996.

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Nevada

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Nevada
                            Taylor/Ward Project:
            Tailings Spill Pollutes Forest Service  Lands
   Sectors:  Lead and Silver

   Facility: Taylor/Ward Project, Alta Gold Company, East Ely, White Pine County, NV

   Facility Overview: Prior to 1984 the site was used to produce silver, by milling, vat
   leaching, and refining.  In 1990, the site was reopened. New operations included
   underground mining, milling, and conventional flotation designed to concentrate a
Waste Stream(s): Tailings.

Waste Management Practices: A tailings line discharged into the tailings impoundment. No
other information was available in the references reviewed for this document.

Type of Impact/Media Affected: In November 1990, a six-inch diameter tailings line
disconnected at a diversion point, allowing the tailings stream to flow into natural drainage
areas rather than into the tailings impoundment.  Thirty thousand  gallons of water carrying 40 to
45 tons of total suspended solids was released. The tailings flowed approximately 1.5 miles
onto U.S. Forest Service land and then an additional 0.3 miles on Bureau of Land Management
land. The tailings deposited down the drainage areas.  Laboratory analysis concluded that the
tails generated acid.  The facility concluded, however, that it was unlikely that surface waters or
ground water were contaminated and that the only environmental impact was of visual nature.

Regulatory Action/Response:  The Nevada Division of Environmental Protection (NDEP)
issued a finding of Alleged  Violation and Order to Alta Gold Company in  November 1990.
NDEP found Alta in violation of Nevada Revised Statutes (NRS) 445.221 "Unlawful discharge of
a pollutant without a permit" and item II. A. 2 of Alta's Water Pollution Control Permit No. NEV
90002, which states that Alta Gold "contain within the fluid management system all fluids
including all meteoric waters which enter the system as a result of the 25 year 24-hour storm
event." The order also required Alta to submit a scope of work to identify the extent of the
contamination.

No comments were received on this comment summary.

References:  U.S. EPA. Draft. Mining Waste Releases and Environmental Effects Summary
for he State of Nevada. May 1992.

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Nevada

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New Jersey
               Glen Ridge and Montclair/West Orange:
            Radioactive Waste Pollutes Residential Soils
   Sectors: Uranium, thorium, and vanadium

   Facility: Glen Ridge, Montclair/West Orange, U.S. Radium, Essex County, NJ

   Facility Overview: These noncontiguous sites were contaminated with radioactive waste
   that may have originated from U.S. Radium, a former radium processing plant.
Waste Stream(s): Mill tailings.

Waste Management Practices: At U.S. Radium, mill tailings were discarded to unused areas
of the main facility and liquids were poured down sewers. Some radium-contaminated soil from
the U.S. Radium site was believed to have been moved and used as fill in nearby low-lying
areas.

Type of Impact/Media Affected:  The single greatest risk associated with these sites was
long-term exposure to radon gas and its progeny (radionuclides).  The transported soil had
exhibited high levels of radium, uranium, and thorium, with contamination down to depths of
more than 10 feet. Radium-226 in soil could have decayed to radon gas, which could have
then  migrated from the soil into houses to decay into particulate radionuclides, increasing the
concentrations of radionuclides in indoor air. Both radon gas and gamma radiation were decay
products of radium that had been detected in these study areas at unsafe levels.  Elevated
background levels of radionuclides were recorded from sediment samples in storm sewers
indicating migration of contaminants via storm sewers.

Regulatory Action/Response: Preliminary investigations to assess the extent of
contamination began in late 1983.  Some houses were equipped with temporary radon
ventilation systems and gamma radiation shielding to reduce indoor exposure to these
radioactive contaminants. Houses were monitored on a quarterly basis for radon decay
products. The New Jersey Department of Environmental Protection had problems obtaining a
disposal facility for excavated materials and soil, forcing the Department to explore alternatives
to excavation. Meanwhile,  all buildings on the U.S. Radium site had been vacated and the
entire area fenced off. Radiation shielding or ventilation systems monitored by EPA were used
until each property was finally remediated.

No comments were received on this comment summary.

References: U.S. EPA.  Draft Final.  Mining Sites on the National Priorities List: NPL Site
Summary Reports. Volume II. June 21, 1991.

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New Jersey

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New Mexico
                   Chino Mine:  Wastewater Overflow
                   and Other Practices  Pollute Creek
   Sector: Copper

   Facility:  Chino Mine, Chino Mines Company, Hurley, NM

   Facility Overview: Chino Mine consisted of an integrated open pit mine and copper
   reduction facility.  The site contained a leach dump and a precipitation plant. A copper
   smelter was also located in the area.
Waste Stream(s): Acid plant blowdown, process wastewater, tailings, slag, and waste rock.

Waste Management Practices: Waste management units and operating practices included
copper leach and waste rock dumps, tailings pond, discharges of acidic water from the
precipitation plant to Whitewater Creek, smelter slag collection areas, discharges from surface1
impoundments holding mine water, and recycling of process wastewater. In May 1986, a power
failure disabled the pumps that were used to recycle process wastewater through the leach
circuit. As a result, process wastewater was diverted to an emergency containment basin (the
Last Chance Reservoir), which eventually overflowed and 16,200 gallons of highly acidic
process wastewater were discharged to Whitewater Creek. Other discharges of acidic waters
to Whitewater Creek had occurred due to heavy rainfall.  According to Phelps Dodge, neither
runoff from the tailings pond nor discharges from the copper leach circuit go to surface waters.

Type of Impact/Media Affected: Over an extended period the Chino Mine site had released
significant quantities of heavy metals and sulfuric acid to Whitewater Creek and to the shallow
and deeper aquifers.  Heavy metals including cadmium, chromium, cobalt, copper, nickel, zinc,
arsenic, manganese, and lead had been detected well above background levels in soil,
creekbed sediments, ground water, and surface water. Elevated levels of sulfate and total
dissolved solids had also been detected in ground water. According to comments by Phelps
Dodge, all of these discharges occurred at permitted outfalls under an existing NPDES permit.

Regulatory Action/Response: The New Mexico Environmental Improvement Division
described the May 1986 spill  as a "serious violation" of state regulations and suggested that the
state would pursue a $10,000 fine. Phelps Dodge states that this discharge was permitted
under the "upset" provision of the facility's NPDES permit. Reportedly, Phelps Dodge and
NMED have entered into a comprehensive Administrative Order on Consent, which covers the
entire mining operation including historical mining impacts that occurred prior to Phelps Dodge's
ownership of the facility. Phelps Dodge also reports the construction of an extensive
stormwater and process water system and the creation of water management contingency
plans to prevent any future release. No information was available on any further regulatory
actions.

Comments were received on this damage summary.  See Appendix A for comment listing and
Agency response.
                                      Page 114

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                                                                New Mexico
References:  U.S. EPA. Draft.  Mining Waste Releases and Environmental Effects Summary
for the State of New Mexico. March 1994.

Pheips Dodge. Comments to Phase IV Proposed Rule on Land Disposal Restriction to Mineral
Processing Wastes. 1996.
                                    Page 115

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New Mexico
                                Tyrone Mine:
             Tailings Dams Contaminate Ground Water
   Sector:  Copper

   Facility:  Tyrone Mine, Phelps Dodge Corporation, Grant County, NM

   Facility Overview:  Tyrone Mine was an open pit mine with a copper mill and leaching
   facility. Mining and milling for copper and other metals began in the late 1960's.
Waste Stream(s): Tailings.

Waste Management Practices: Tailing dams extended several miles down the valley in
natural drainages.  The dams were constructed along the natural drainages of the creek, and, in
some cases, deposited on alluvium in tributaries.                                     -  •

Type of Impact/Media Affected:  In 1989, increasing levels of Total Dissolved Solids (TDS)
and sulfate were observed in two of the facility's ground water monitoring wells.  Based on
tailing dam deposition and seepage records,  Phelps Dodge estimated that average flow to the
ground water system from tailing dam seepage from  1978 to 1989 was 4,270 acre feet per
year. Additional sources of inflow included seepage from tailings decant ponds, related decant
systems, and leaching operations.  Phelps studies concluded that oxidation of the tailings,
accelerated oxidation of materials associated with historic mining activities in the area, as well
as current mining operations, were  potential sources  of elevated TDS and sulfate
concentrations near the top of the unconfined aquifer. According to Phelps Dodge, no mineral
processing operations were conducted at the Tyrone Mine.

Regulatory Action/Response: The state made renewal of Phelps Dodge's Mangas Valley
Discharge Plan contingent upon Phelps Dodge investigating the TDS/sulfate ground water
problem.

Comments were received on this damage summary.  See Appendix A for comment listing and
Agency response.

References: U.S. EPA. Draft. Mining Waste Releases and Environmental Effects Summary
for the State of New Mexico. March 1994.

Phelps Dodge. Comments to Phase IV Proposed Rule on Land Disposal Restriction to Mineral
Processing Wastes.  1996.

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New Mexico

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North Carolina
                         Aurora Phosphate Plant:
                     Wastewater Overflow Kills Fish
   Sector: Phosphoric acid

   Facility: Aurora Plant, Texasgulf Chemicals Company, Aurora, NC

   Facility Overview: Since at least 1973, the plant had produced calcined and dried
   phosphate rock, sulfuric acid, phosphoric and superphosphoric acid, and other phosphate
   fertilizer ingredients.
Waste Stream(s): Gypsum waste and process wastewaters.

Waste Management Practices:  Waste management units at the plant included clay slurry
settling ponds, two unlined cooling water ponds, gypsum stacks, and clay blend piles, which"
contained a mixture of clay and gypsum.

      The process of purifying the ore involved separating very fine clay particles from
phosphate rock. The clays left the separation process as a water based slurry that was
referred to as "slimes." They were hydraulically transferred to settling ponds where the clear
water fraction was separated and discharged. The facility had five settling ponds that
discharged to South, Bond,  and Long Creeks via 12 permitted outlets.

      Two cooling water ponds were used to recirculate process water through the phosphoric
acid and fertilizer manufacturing areas, where it was used primarily in acid dilution, cooling,
gypsum slurrying, and operation of emission  control devices. Pond No. 1, with a surface area
of 120 acres, began operation in November 1966.  Pond No. 2, with a surface area of 9.7
acres, began operation in late 1973.

      There were six gypsum stacks or piles located on the plant site.  The stacks, which
cover approximately 41 acres, were surrounded by a ditch that returned excess water from the
stacks to Pond No. 1.  There were also a number of gypsum-clay blend piles (designated R-1,
R-2, R-4, and R-5) on the site that were used in land  reclamation activities.

Type of Impact/Media Affected: Texasgulf investigations had focused on leakage from
cooling ponds Nos. 1 and 2, which had resulted in ground water contamination of the first two
water-bearing zones at the site.  In 1988, Texasgulf commissioned a Preliminary Contaminant
Assessment for Cooling Ponds 1 and 2 in fulfillment of requirements for the renewal of a zero
discharge permit. As part of this study, Texasgulf installed 21 monitoring wells at the site in
March and April of 1988.  These monitoring wells included 10 wells at Cooling Pond No. 1, nine
wells at Cooling Pond No. 2, and two background monitoring wells.

      Initial ground water samples obtained from monitoring wells at each of the cooling ponds
during April 1988 showed contamination in the surficial aquifer and the Croatan Aquifer, which

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                                                                North Carolina
underlaid the surficial aquifer at the site. Texasgulf subsequently began additional
investigations to delineate the areal extent of contamination.  The first zone appeared to be
discharging to the facility's main effluent canal, while the direction of ground water flow in the
next zone was toward Pamlico Sound.  Texasgulf subsequently began additional investigations
to delineate the extent of contamination. Initial results appeared to support the initial conclusion
that contamination was confined to the upper two water-bearing zones and that the Yorktown
formation had prevented downward migration  of contamination.

Regulatory Action/Response: The North Carolina Department of Environmental
Management had recorded a number of incidents dating back to 1980 at the plant that may
have harmed the environment. These incidents  included violations of Texasgulf s effluent
permit and spills from the facility.  For example, violations of the effluent permit for daily
maximum phosphorus and fluoride were recorded in 1980 on March 12, March 13, December
9, and December 11.  Daily maximum permit limits were 9 mg/L for phosphorus and 10 mg/L
for fluoride. Recorded concentrations for the four days ranged from 11  to 34 mg/L for
phosphorus. Fluoride concentrations were 12 mg/L on March 12 and March 13.  These
violations occurred when contaminated wastewater from the toe ditch of the gypsum pile
overflowed into the company's fresh water system. A spill of 40 million  gallons of gypsum stack
decanted water into a nearby fresh water canal occurred on January 4,1987, when a retaining
dike around one of the gypsum stacks failed. A 24-hour analysis of the canal water showed- a •
pH drop to a low of 4.2, with a two-hour period when pH was below 6.0. At least 18 dead fish
were counted along the canal.  The company was fined $1,000 for the incident by the State of
North Carolina.

No comments were received on this comment summary.

References:
U.S.  EPA. Report to Congress on Special Wastes from Mineral Processing Facilities.  Volume
II: Methods and Analyses. July 1990.

U.S.  EPA. Report to Congress on Special Wastes from Mineral Processing. Technical
Background Document:  Damage Case Investigation.  July 1990.

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North Dakota
                 Great Plains  Coal Gasification Plant:
              Gasifier Ash Contaminates Ground Water
   Sector: Coal gasification

   Facility: Great Plains Coal Gasification, Plant, Dakota Gasification Company, Beulah,
   Mercer County, ND

   Facility Overview: The coal gasification facility produced synthetic natural gas that was
   sent to a refinery for processing as a natural gas.
Waste Stream(s): Ash from Lurgi gasifiers.

Waste Management Practices: Ash from the gasifier was quenched with blowdown from the
wet scrubber system on the facility's incinerator and sluiced into one of four ash sumps where .
the ash was settled from the slurry. The liquid recovered during the ash dewatering was
recycled back to the ash quench and sluicing area or used as makeup water to the liquid waste
incinerator. The dewatered ash was trucked to  an on-site landfill.

      SU-101 was the active portion of the landfill that received gasifier ash.  Large pits within
the SU-101 area were utilized for the disposal of the gasifier ash and other waste streams.
According to the North Dakota State Department of Health and Consolidated Laboratories
(NDSDHCL), at least 90 percent of all waste disposed in SU-101 consisted of gasifier ash.
Excess liquids from the gasifier ash disposed in area SU-101 flowed with any additional run-off
to the adjacent sumps and may have been later pumped to the evaporation pond. Analytical
data from August 1989 show that the pH of water in the sump ranged from 12.7 to 13.7, while
the arsenic concentration ranged from 13.8 mg/L to 22.0 mg/L, and the selenium concentration
ranged from 1.1 mg/L to 2.2 mg/L.

Type of Impact/Media Affected:  The plant site was located on a broad valley that was
underlain by the Antelope Valley or Beulah Trench aquifer. The Beulah Trench interconnected
with the  aquifer associated with the Knife River Valley, which served as a water supply source
for the communities of Beulah and  Hazen, located approximately nine miles south and 14 miles
southeast of the plant site, respectively. The  mine used as the coal supply for the plant was
located immediately east of the facility.

      In December 1985, NDSDHCL expressed concerns to ANG (the former owner of the
facility) regarding the levels of water in the run-off pond within the ash storage area,  because  of
high pH  and high arsenic content in the run-off water. The Department stated that the disposal
of gas ash containing excess liquids must be  discontinued immediately.

      According to quarterly monitoring reports submitted by DGC to NDSDHCL from April
1988 to June 1989, monitoring wells around a portion of the landfill area indicated significant
differences in  concentrations between downgradient and upgradient wells.  From five to six total

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                                                                  North Dakota
samples taken from upgradient wells 15, 16, and 17, Electrical Conductivity (EC) averaged
4,790 /^mhos/cm; sulfates (SO4) averaged 1,248 mg/L; and total dissolved solids (IDS)
averaged 3,638 mg/L.  From eight total samples taken from downgradient wells, 14, 18 and 24,
EC averaged 11,870 pmhos/cm; SO4 averaged 7,056 mg/L; and IDS averaged 11,569 mg/L.

       Monitoring well  analytical data in a DGC report dated February 22, 1989, indicated that
three additional wells near the ash disposal area had exhibited "increased concentrations" of
some constituents.  Analysis of samples from one of these wells revealed increased mean
specific conductance (15,000 pmhos/cm), as well as increased mean concentrations of sodium
(3,000 mg/L), sulfates (11,000 mg/L), and IDS (17,000 mg/L). Background, or upgradient data,
were not provided.  The other two wells contained similar concentrations, and over a period  of
one year or less, historical data documented increases in these constituent levels (see exhibit
below).

Regulatory Action/Response:  In July 1987,  NDSDHCL Division of Waste Management and
Special Studies prepared a memorandum that summarized letters written and inspections
conducted relating to ANG's gasifier ash dewatering system and disposal area.  This
memorandum requested the issuance of an NOV to ANG for improper waste handling
procedures relating  specifically to the dewatering of gasifier ash, the unauthorized placement of
associated liquids and sludges having potentially hazardous characteristics in the gasifier ash .
disposal area, and the spillage of ash, liquids and sludges during their transport from the
dewatering area to the  ash disposal area. The memorandum discussed ANG's violations of the
state's Solid Waste Management rules, including the unauthorized placement of liquid and
semi-liquid wastes in a  landfill not permitted for such wastes, the unauthorized improper
construction and operation of the disposal site, the  inadequate protection of surface water in
violation of permit conditions, and the spillage of liquids, sludges, and ash during transport. As
stated in the memorandum: "ANG's [practices have].  . .  increased the potential for ground
water degradation and  [have] probably resulted in some surface water degradation."

       According to the NDSDHCL, Dakota Gasification discontinued the use of unlined ponds
for the disposal and storage of liquid-bearing wastes in 1988.  Ponds since mid-1988 had  a
liner.

       Department inspections of the DGC facility in October and November 1989 cited DGC
for constructing an industrial waste landfill that did not meet requirements of the renewed
permit, and for noncompliance with the North Dakota Solid Waste Management Rules.  The
reference did not contain any discussion of any fines or NOVs for the facility's waste
management practices.

               Increases in Concentrations of Selected Constituents
         in Two Gasifier Ash Disposal Area Monitoring Wells (1987 -1988)
Well
W04018
Net Increase in Parameter Value Between Sampling Periods
Cl
(mg/L)
3,910
SO4
(mg/L)
840
Na
(mg/L)
1,125
Spec. Cond.
(pmhos/cm)
11,290
IDS
(mg/L)
—

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North Dakota
W04020
2,114
525
877
5,200
3,759
No comments were received on this comment summary.
References:  U.S. EPA. Report to Congress on Special Wastes from Mineral Processing
Facilities.  Volume II: Methods and Analyses.  July 1990.

U.S. EPA. Report to Congress on Special Wastes from Mineral Processing. Technical
Background Document:  Damage Case Investigation. July 1990.

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isforth Dakota

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Northwest United States
                             Confidential Site:*
         Drinking Water Contaminated at Phosphate Mine
   Sector: Phosphate

   Facility: Confidential

   Facility Overview: The site was involved in mineral processing. The facility extracted
   and stored phosphorous before shipping.
Waste Stream(s): Process wastewaters generated from production of phosphate, which were
exempt under Section 3001b(3)(A)(ii) of RCRA.

Waste Management Practices: About 50 percent of the waste slag was sold for use as
highway construction material, and the remainder was deposited on two on-site waste piles.
Other waste was crushed, stored on bare ground, and later sold for its vanadium, iron, and
chromium content. The remaining wastes were deposited in on-site ponds.  The facility also
had a landfill.  On-site run-off was discharged to a nearby river after being mixed with boiler
blowdown water in the unlined lagoon.

      The site contained two gypsum stacks, an unlined liquid gypsum pond, an unlined
cooling pond, and three lined wastewater treatment ponds. The ponds were used to collect and
treat all unrecycled wastewater. Another pond received boiler blowdown cooling water and
some surface run-off, which was then piped to the wastewater treatment plant.

Type of Impact/Media Affected:  The metals detected in the ground water corresponded to
those elements (arsenic, cadmium, and zinc) detected at high concentrations in the unlined
waste ponds.  Contaminants had been detected in a nearby spring, used for drinking water at a
local cafe, which was consequently condemned, and the river, used for recreation and
irrigation.

Regulatory Action/Response: Several site investigations had quantified the effect of mineral
processing on the surrounding environment.  During the early 1970s, a ground water monitoring
study conducted by the state detected levels of arsenic, cadmium, and lead above the Federal
Primary Drinking Water Standards. A subsequent  Environmental Impact Statement (EIS)
prepared by the United States Geological Survey also documented contamination. In addition,
an EPA inspection report stated that 50 drums of PCS contaminated material was landfilled on-
site.  A more recent site inspection noted a cone of depression in the two main aquifer systems
from high rates of pumpage.  A Draft Health Assessment had been completed. The site is on
the NPL.
  '_ This site is classified as confidential because of impending enforcement^ction.

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                                            Northwest United States
No comments were received on this comment summary.

References: U.S. EPA. Draft. Final Mining Waste NPL Site Summary Reports. June 21,
1994.

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Ohio
                          ASARCO Zinc Smelter:
              Acutely Toxic Releases to Surface Water
    Sector: Zinc

    Facility:  ASARCO, Columbus, OH

    Facility Overview: American Zinc Oxide owned the smelter from 1918 to 1970, when
    ASARCO purchased the property in 1971 and operated it until ceasing production in
    1986. The facility produced zinc oxide.
Waste Stream(s): Zinc slag.

Waste Management Practices: The facility produced zinc oxide from sphalerite ore by
oxidation, reduction, and back oxidation.  Until recently, it appeared that all zinc slag was
disposed and/or stored on-site when ASARCO began selling its slag for further zinc recovery to
Horsehead Resources. ASARCO reports that in 1987 it had shipped approximately 40,000
tons of slag off-site. In 1990, ASARCO estimated that at least 50,000 tons of slag were
distributed throughout the site, mainly in two piles-the northern and southern piles.

      Run-off from the facility drained to an open ditch near Joyce and 12th Avenues, referred
to as the Joyce Ave. outfall. The receiving ditch, referred to as the American Ditch, flowed
about one mile through an industrial and  residential area. Until June 1989, when the American
ditch was diverted to discharge directly to Alum Creek, flow from the American ditch entered the
combined sewer of the City of Columbus. Alum Creek was classified as a primary contact,
warm fishery, public, industrial, and agricultural water supply.

Type of Impact/Media Affected: In 1972, the City of Columbus found that its wastewater
treatment facility was receiving excessive zinc and cadmium loadings from water originating at
the ASARCO smelter site. Investigations eventually led to the conclusion that run-off and
leachate from the on-site zinc slag were responsible for the excessive loading. Water samples
taken by the City of Columbus from the American Ditch, which bisects the facility, showed
cadmium and zinc concentrations above  limits established by the City. Dissolved cadmium
measured 0.56 mg/L while dissolved zinc measures 92.0 mg/L; the recorded pH was 2.6.

Regulatory Action/Response: A 1981 analysis performed by the City of Columbus on
ASARCO's discharge to the American Ditch showed that the discharge exceeded by several
times the 3.0 mg/L City limit for zinc and that cadmium concentrations were also above the 0.5
mg/L City limit. ASARCO was cited by the City for violations of discharge limits for cadmium
and zinc into the sewer system.

      Slag area run-off sampling data for September and October 1986 revealed zinc
concentrations of 26 mg/L and 46 mg/L, respectively.  At that time, ASARCO agreed to begin
removing the zinc slag from the facility.  In August  1987, the Ohio EPA described the situation
at this facility by stating that, "[d]ue to past practices over many years of dumping waste slag or

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                                                                              Ohio
clinker all over the site, there was still a problem with contaminated run-off.  There were
documented problems with high concentrations of zinc and cadmium in the run-off." In
November 1987, ASARCO notified the City of its shipment off-site of 35,000 tons of zinc slag.

       Subsequent testing had shown that the release of contaminants into surface waters
continued. An Ohio EPA inter-office communication from June 1988 included a report which
stated that "overall analysis of cadmium and zinc concentrations from the Joyce Avenue outfall
[ASARCO's discharge to the American Ditch] suggests acutely toxic conditions exist on a
frequent basis."  For zinc, 20 percent of water samples (5 percent for cadmium) taken from the
ASARCO treatment center outfall were reported to have exceeded the Final Acute Value limits
(188 f^g/L for cadmium and 1,298 ^g/L for zinc) established for American Ditch to  protect
against rapidly lethal conditions within a water body.

       According to ASARCO, the Ohio EPA has conducted several bioassays since 1988 on
the effluent from the waste water treatment plant used to treat stormwater. Reportedly, the
results show that the discharge is acutely toxic to Ceriodaphina. Bioassay results on water
from Alum Creek reportedly pass for both Ceriodaphnia and fathead  minnows.

Comments were received on this damage summary.  See Appendix A for comment listing and
Agency response.                                                                 _  .

References:  U.S. EPA.  Report to Congress on Special Wastes from Mineral Processing
Facilities.  Volume II:  Methods and Analyses.  July 1990.

ASARCO.  Comments to Phase IV Proposed Rule on Land Disposal Restriction to Mineral
Processing Wastes. 1996.

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Oregon
                   Martin Marietta Reduction Facility:
           Aluminum Production Facility Placed on NPL
   Sector: Aluminum

   Facility: Martin Marietta Reduction Facility (MMRF), The Dalles, Wasco County, OR

   Facility Overview: The facility began operating in 1958. Aluminum production from
   alumina took place in a reduction cell, outlined with alumina insulation and carbon
   potlining. An electrical current was passed through a solution of aluminum oxide
   dissolved in a bath of molten crystolite. The aluminum and oxygen separated with
   aluminum forming on the cathodic surface.
Waste Stream(s): Asbestos, metallic wastes, spent cathode-waste materials containing
cyanide, polynuclear aromatic hydrocarbons (PAHs), and arsenic.                      "  '

Waste Management Practices: Wastes were generated from spent cathodes and anodes
utilized in the alumina reduction process. Waste management from 1958 to 1972 involved
washing and temporarily storing spent cathodes, which were shipped off-site via railroad.  From
1972 until 1984, wastes were disposed of on-site.

      A landfill occupied approximately 15 acres immediately north of the alumina reduction
building.  Wastes were randomly deposited on the ground surface.  A leachate-collection
system controlled the amount of leachate generated by the landfill.

      In 1958, a scrubber system began generating air emission-control sludge containing
high levels of fluoride, sulfate, and PAHs. The scrubber sludge was either discharged to a pond
to settle out particulates or recycled into production.

      Surface water ponds at the site included four scrubber sludge ponds, the Recycle Pond,
and the Lined Pond.  The Recycle Pond served as a collection point for run-off from the Landfill,
the Old Cathode-waste Management Area, and areas immediately south and west of the
alumina  plant. The Recycle Pond discharged into the Columbia River under a NPDES permit.
The Recycle Pond was used to control surface water run-off, but was not an active part of the
plant's wastewater recycling system.  Similarly, the Lined Ponds were no longer in use as  part
of the plant's production operation due to remediation.

Type of Impact/Media Affected:  Ground water samples taken in various areas of the site had
identified total and free cyanide, fluoride, sodium, and sulfate. Potentially unacceptable
carcinogenic risks from exposure or direct contact were expected in certain areas of the site.
PAHs had been detected in landfill soils, surface drainage ditch sediments, soils in the Potliner
Handling Area,  sediments in the Discharge Channel, and pond sediments in the Scrubber
Sludge Ponds.

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                                                                        Oregon
Regulatory Action/Response: MMRF was placed on the NPL in 1987.  The remedial
alternative selected by EPA included institutional controls such as deed restriction and fencing.

No comments were received on this comment summary.

References: U.S. EPA.  Draft Final. Mining Sites on the National Priorities List: NPL Site
Summary Reports. Volume III.  June 21,  1991.

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Oregon	


   Teledyne Wah Chang Albany:  Ground and Surface Water
          Contaminated by Metals Manufacturing Wastes
  Sectors: Hafnium, niobium, tantalum, vanadium, and zirconium

  Facility: Teledyne Wah Chang Albany (TWCA), Millersburg, Albany County, OR

  Facility Overview: Since 1956, the facility has been a primary manufacturer of zirconium
  metal.  Zircon sand underwent a chlorination process producing zirconium tetrachloride
  and silicon tetrachloride. Methyl isobutyl ketone (MIBK) was added to remove the
  hafnium portion of the zirconium. The resulting oxides underwent a second chlorination
  step, a reduction process using elemental magnesium, and consolidation of zirconium
  sponge into ingots.
Waste Stream(s): Sand chlohnator residues, MIBK still bottoms, magnesium chloride wastes,
smokehouse residue, and slag wastes containing niobium and iron metals.

Waste Management Practices: TWCA operated a wastewater treatment system consisting of
a continuous chemical precipitation and sedimentation. The system generated treated
wastewater and sludges to handle industrial wastewaters resulting from metals manufacturing.
The treated wastewater was discharged to Truax Creek, while sludges were placed in storage
ponds for additional settling and dewatering.  Until 1979, solids produced from the treatment
processes were stored in the settling ponds.

      TWCA obtained a solid waste permit to use the sludge as a soil amendment on the
TWCA Farm  Site in 1976. In 1979, the Farm Ponds operated as solids storage ponds for
sludge from the wastewater treatment processes. Modification of the production process
reduced the concentrations of radioactive materials in the sludges, directing them to a separate
solid waste stream that was shipped to Hanford, WA for disposal.

      Solid wastes were initially delivered to the Dumpmaster Area, where they were
inspected and separated into nonhazardous and hazardous components. The former were
disposed of at a public landfill, whereas the hazardous wastes were stored on-site until they can
be transported off-site to a hazardous waste storage, treatment, or disposal facility.
                                                      i
      TWCA also operated three on-site areas for the disposal of solid waste. Chlohnator
residue was stored in a pile until 1978 when the waste had been transferred to Hanford, WA.
Solid residues from the nonfenrous metals manufacturing process were placed in the
magnesium resource recovery pile until May 1983. Later that year, TWCA began operations to
recover and beneficially use the contents of the pile.

Type of Impact/Media Affected:  Ground water samples collected in the area of the farm
ponds found  concentrations of heavy metals (including cadmium, chromium, and lead)
exceeding the Federal Primary Drinking Water Standards.  The maximum concentrations for

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                                                                         Oregon
chloride, iron manganese, sulfate, and IDS exceeded federal Secondary Drinking Water
Standards.  Sample data indicated low levels of volatile and semivolatile organic compounds in
the surface waters on and around the site. Specifically, Chloroform and 1,2-dichloroethane
exceeded the surface water Ambient Water Quality Criteria (AWQC) for water and fish
ingestion.

      A general assessment of risks for the entire TWCA site included the threat to workers by
radon gas, the potential that flooding could have caused widespread contamination of
radioactive wastes, the contamination of the land by the application of radioactive materials,
and the potential for ground water and surface water contamination.

Regulatory Action/Response:  TWCA had water and air emission permits. The facility had
been cited for numerous violations of its NPDES permit.  TWCA was assessed fines for other
water quality permit violations in 1979, 1980, and 1989. The company was fined for illegal open
burning in 1983. In October of 1983, TWCA was listed on the NPL.  TWCA was cited  for
several violations of Oregon's hazardous waste management rules in 1986.  In May of 1987,
TWCA signed a Consent Order to conduct a Remedial Investigation/Feasibility Study.

No comments were received on this comment summary.

References: U.S. EPA. Draft Final. Mining Sites on the National Priorities List:  NPL Site
Summary Reports. Volume V.  June 21, 1991.

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 Pennsylvania
                              Aliquippa Works:
                   High pH in Ground Water Leachate
   Sectors:  Iron/steel

   Facility: Aliquippa Works, Jones and
   Laughlin Steel Corporation (J&L, or LTV
   Steel), Aliquippa, Beaver County, PA

   Facility Overview: The Aliquippa Works
   was closed around 1985.  When
   operational, the Aliquippa facility contained
   both blast furnace and basic oxygen
   furnace operations.
Waste Stream(s): Blast furnace and basic
oxygen furnace slag.

Waste Management Practices: The
Black's Run area had served as a storage
and disposal site for over 40 years.  In
1980, J&L commenced operation of a
RCRA Subtitle C landfill within the Black's
Run site for disposal of certain designated
hazardous wastes generated by J&L's iron-
and steel-making processes. The primary
hazardous waste disposed at Black's Run
was air pollution-control dust from electric
arc steelmaking furnaces at J&L's
Cleveland and Pittsburgh Works.
      The disposal cell was lined with multiple layers:  a two foot layer of basic oxygen furnace
slag, covered with one and one half feet of low permeability flyash, and topped with a three foot
layer of slag. The landfill was constructed on a slope, directing leachate downward to be
collected and treated at the 'toe1 of the slope.

Type of Impact/Media Affected: Documented environmental impacts had occurred in two
general areas of the site. The first area was the Black's Run Landfill, which was lined with basic
oxygen furnace slag.  Leachate from this landfill had entered Black's Run Creek.  The second
area was the Aliquippa Works facility itself. At least a portion of the facility was underlain by
blast furnace slag, which had a thickness of 52 feet in some places. This blast furnace slag
was contaminating shallow ground water that seeped into surface water.

      Basic Oxygen Furnace Slag

      By  1982, Pennsylvania Department of Environmental Regulation (PADER) investigators
found indications that  leachate from the landfill was discharging into the East Fork of Black's
Run Creek, and that a white precipitate had been deposited on the stream bottom downstream
of the landfill. The inspector reported that the leachate was apparently not from the electric
furnace dust and sludge, but rather from the slag and ash liner. This white deposit, attributed to
the slag  liner, was noted in 1987 and 1988 as well.

      Samples taken in March 1987 showed Black's Run Creek upstream of the landfill at a
pH of 8.43, and total dissolved solids (TDS) at 597 mg/L. Downstream of the landfill, the pH of
Black's Run was elevated to 12.30 and TDS to 1,925 mg/L. Monitoring well sampling on this
same date showed a significant increase in pH from the upgradient shallow Well at a mean of
7.71 to the downgradient shallow well at a mean of 9.29, exceeding the National Secondary
Drinking Water Regulations maximum  pH level of 8.5. Analytical data for parameters other than
pH and TDS were not contained in the available documents.

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                                                                  Pennsylvania
       In a June 1988 inspection report, the PADER inspector noted that visible impacts to the
Black's Run Creek occurred much farther downstream than when they had been first noted
several years previously. The inspector found the creek bottom covered with precipitate for
approximately 500 yards downstream.  The PADER inspector also stated that little aquatic life
was evident in the creek from the point where it passed the landfill until well below all the seeps,
close to where the stream goes under Route 51.  In June 1988 another inspector found erosion
problems on the soil cap of the closed landfill, and an unsatisfactory revegetation status.

       Blast Furnace Slag

      As mentioned previously, the Aliquippa Works facility itself was constructed on blast
furnace slag fill, which was at least 52 feet thick in some places.

       In a cover letter for monitoring data submitted by LTV to PADER, LTV discussed
elevated pH and TDS values in seep samples, stating that such values "are not unexpected
from areas where the slag was placed for fill." Analytical data from these seeps from 1977
through 1985 showed pH values ranging from 12.1 to 13.1, while TDS values ranged from
1,370 mg/L to 3,508 mg/L.

      In a letter to PADER in December 1987, LTV discussed its NPDES violations.  LTV .  .
reported two outfalls discharging water with pH values of 10.9 and 10.4, exceeding the
maximum  permitted pH of 9.0.  LTV explained that "the fill in the area of the two outfalls is all
blast furnace slag.  This would cause high pH in rainwater entering the now idled sewers."

      LTVs November 1988 NPDES monitoring results submitted to PADER indicated an
exceedance of the maximum permitted pH level of 9.0 in an outfall with pH 9.4. LTV again
explained that the Aliquippa Works was built on slag fill.  LTV noted that since no operating
facility uses the sewer of concern, ground water from the slag filled areas was probably
infiltrating the sewers and causing the high pH.

Regulatory Action/Response: The landfill was closed in September 1987 because its slag
liner did not meet the revised standards for an operating permit. Closure  activities involved
regrading, capping with a clay/soil layer, and securing the. area with a fence. Monitoring wells
were installed around the landfill at depths to monitor both the shallow aquifer and a deeper
aquifer.

References:  U.S. EPA.  Report to Congress on Special Wastes from Mineral Processing
Facilities.  Volume II:  Methods and Analyses. July 1990.

No comments were received on this comment summary.

U.S. EPA. Report to Congress on Special Wastes from Mineral Processing. Technical
Background Document: Damage Case Investigation. July 1990.

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Pennsylvania
                         Foote Mineral Company:
                  Lithium Detected in Ground Water
  Sector: Lithium

  Facility:  Foote Mineral Company, East Whiteland Township, PA

  Facility Overview:  Since 1941, the site has produced lithium chemicals; other processed
  lithium metal produced lithium bromite, chloride, and fluoride; and manufactured pre-fused
  fluxes.
Waste Stream(s):  Process wastes (Cyprus claims that the source of the lithium is unknown)

Waste Management Practices:  The site contained three unlined settling ponds, a burn pit,
two quarries, and an area where containers of lithium arsenite were buried. A quarry was filled
with 120 million pounds of process waste material, including 60 tons of calcium aluminum
silicate.  Cyprus Mineral Co. excavated and treated 15,000 sq. yds. of soil using a bioremedial
technique in 1992.

Type of Impact/Media Affected:  The contaminated media included soil, surface water, and
ground water. Ground water sampling in 1988 detected high lithium concentrations, as well as
arsenic,  hexavalent chromium, and antimony contamination. These contaminants were also
detected in surface water samples in 1984.

Regulatory Action/Response:  No regulatory actions were discussed in the reference
reviewed.

Comments were received to this damage summary.  See Appendix A for comment listing and
Agency response.

References: U.S.  EPA.  Draft. Mining Sites on the NPL  August 1995.

Cyprus.  Comments to Phase IV Proposed Rule on Land Disposal Restriction to Mineral
Processing Wastes. 1996.

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Pennsylvania

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Pennsylvania
                               Palmerton Zinc:
           Enormous Waste Pile  Pollutes Soil and Creek
  Sectors: Lead and zinc

  Facility: Palmerton Zinc, Borough of Palmerton, Carbon County, PA

  Facility Overview: Two primary zinc smelters produced zinc and other metals for
  machinery, Pharmaceuticals, pigments, and other products from 1898 to 1987.  The first
  smelter produced zinc oxide and the second smelter concentrated zinc sulfide ores.
Waste Stream(s): Process residues (cinders) and other wastes.

Waste Management Practices: From 1898 to 1970, process residues, other plant wastes,
and municipal wastes were deposited at a cinder bank waste pile located behind the East Plant.

Type of Impact/Media Affected: The Palmerton Zinc Superfund site had four problem areas:
(1) The Cinder Bank; (2) The defoliated portion of Blue Mountain near the smelter slag piles; (3)
Heavy metal deposition throughout the valley; and (4) The overall ground water and surface
water contamination. The first two operable units had been investigated.

      Surface-soil samples collected in the Blue Mountain Operable Unit recorded levels of
cadmium, lead, and zinc at 2,600, 2,000, and 400 times the regional background levels,
respectively. Vegetation damage first appeared in 1951  as isolated patches on the steep,
north-facing slope of Blue Mountain. By 1985, approximately 2,000 acres had sustained
vegetation damage (i.e., areas of exposed rock and soil leaving barren, eroded land visible).
Water flowing off the defoliated portions of the Blue Mountain had eroded the surface and
become contaminated with metals in the soil.  The run-off and erosion had carried the metal-
ladened soil into Aquashicola Creek, which was stocked with trout annually.

      Process residues and other plant wastes were deposited on the Cinder Bank until it had
become 2.5 miles long, between 500 and 1,000 feet wide, and up to 100 feet above the mineral
soil layer.  In December 1986,  it was estimated to contain 28.3 million tons of leachable metals
including lead, zinc, and cadmium.  Contaminated leachate percolated down to the ground
water and seeped out of the Cinder Bank.

Regulatory Action/Response:  Palmerton Zinc was added to the NPL in September 1983. In
compliance with the EPA's Administrative Order by Consent, dated September 24, 1985,
sampling of all affected media was conducted on behalf of the New Jersey Zinc Company, by
R.E. Wright Associates, Ina In a February 6,  1987, memorandum, the Agency for Toxic
Substances and Disease Registry found that a potential human health risk existed through the
consul-option of fish from Aquashicola Creek.
No comments were received on this comment summary.

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                                                             Pennsylvania
References: U.S. EPA.  Draft Final.  Mining Sites on the National Priorities List: NPL Site
Summary Reports. Volume IV. June 21, 1991.

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South Carolina
              Brewer Gold Mine:  Cyanide Release from
                Gold Mine Affects Biotic Communities
   Sector: Gold

   Facility: Brewer Gold Mine, Brewer Gold Mine Company, a subsidiary of Westmont
   Mining Inc., Jefferson, Chesterfield County, SC

   Facility Overview: Gold mining operations included heap leaching, carbon adsorption,
   and electrowinning. Ore was hauled to on-site crushers, agglomerated, and conveyed to
   a heap leach pad, where a cyanide solution was used to recover gold.
Waste Stream(s): Spent leaching solution.

Waste Management Practices: Seven heap leach pads were rinsed to reduce cyanide levels
and pH.  Leacnate collected from the leach heaps was run through carbon adsorption columns.
Lined ponds held barren, pregnant, and rinse solutions.                               _  .

Type of Impact/Media Affected:  Since the opening of the facility in July 1987, the spills and
other incidents included finer ruptures, leach pad collapses, barren solution hose breakages,
solution  line ruptures, pond discharges, ore slides, pipe leakages, and dam failures.  In October
1990, a tropical storm caused a 10 to 12 million gallon, 100 mg/L cyanide solution release. A
study conducted in March 1991 pursuant to an EPA order indicated that the macroinvertebrate
and fish  communities in Little Fork Creek and Fork Creek downstream of the October cyanide
release continued to show signs of the release's impact.  While Lynches River showed
improvement,  sampling locations on Little Fork Creek showed little to moderate improvement in
terms of biotic organisms.

Regulatory Action/Response: The South Carolina Department of Health and Environmental
Control (DHEC) and the Land Resources Commission (LRC) were notified of each incident and
responded to each with Consent Orders and fines. In October 1990, a precautionary statement
was issued by the state that asked people not to drink, bathe, swim, or water livestock in
affected waters due to the dam failure. Subsequently, EPA Region 6 issued an Administrative
Order and the state issued Consent Order 91-30-W to the Brewer Gold Company.  EPA's order
required a remediation plan for sampling in the discharge area and stream sediment in Little
Fork Creek, Fork Creek, and Lynches River to determine if remediation of soil or sediments was
necessary. A  State Notice of Enforcement Conference listed specific violations of NPDES limits
and of requirements to obtain permits, all of which Brewer claimed were without basis.  In the
Consent Order, Brewer agreed to submit status reports on waste management practices and
pay a civil penalty or $50,000.  DHEC and LRC issued (or modified) permits for the redesign
and reconstruction of the overflow pond and  dam.  In addition, LRC required Brewer to retain a
qualified independent professional engineer to determine the cause of the dam failure and to
review the design for the replacement dam.
No comments were received on this comment summary.

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                                                           South Carolina
References: U.S. EPA.  Draft. Mining Waste Releases and Environmental Effects Summary
for the State of South Carolina. March 1994.

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South Dakota
                              Gilt Edge Project:
               Liner Leaks Contaminate Ground Water
  Sector: Gold

  Facility: Gilt Edge Project, Brohm Mining Company, Deadwood, SD

  Facility Overview: The facility included an open pit mine, an on-off leach pad and
  associated solution ponds, a gold recovery plant, and spent-ore and waste rock piles.
  Leaching operations began in October 1988.
Waste Stream(s): Spent barren solution.

Waste Management Practices: The heap leach was divided into seven cells. The original
lining system at the base of the leach pad included a primary and a secondary liner with a
leakage detection, collection, and removal system drainage layer.  A seven million gallon surg6
pond was used to store both pregnant and barren solution. Primary liners under several leach
cells leaked during initial leaching operations. To eliminate the risk of future leakage, Brohm
began hauling process solution from the surge pond to Homestake Mine's tailings facility. A
reverse osmosis unit was installed to treat excess solution to levels below South Dakota ground
water quality standards.  Cyanide releases caused Brohm to construct two unlined containment
ponds to collect released solution.  Brohm then neutralized the cyanide with hydrogen peroxide.
A bioremediation plan was approved by the state for contaminated soils and ground water.
Brohm also began extensive monitoring of nearby ground and surface water.

Type of Impact/Media Affected: Several spills  had released cyanide solution, ponded
solution, and spent ore to the environment. Results of regularly scheduled surface water
monitoring showed detectable levels of cyanide in Strawberry Creek immediately downstream
of the processing facilities and Bear Butte Creek. Cyanide was also detected in local ground
water.  In addition, six dead birds were found in the surge pond in 1991.

Regulatory Action/Response: The state conducted numerous inspections between  1988 and
1990. Two Notices of Violation (NOVs) were issued to Brohm. The first NOV in 1988 required
the facility to suspend active leaching and repair  the primary liner.  After extended discussions,
the state and Brohm reached a settlement agreement where the facility agreed to pay a fine of
$100,000 and the state withdrew the 1988 NOV because no damage to human health and the
environment had occurred. The second NOV in  1991 was issued after ground water
contamination was detected.  It required the facility to stop releasing process solutions,
complete installation of the VLDPE liner, and characterize the extent of ground water
contamination. Because of the levels of cyanide discharged and detected in ground water and
surface water, the state maintained frequent contact with the facility and conducted numerous
investigations that included sampling and analysis.

No comments were received on this comment summary.

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                                                            South Dakota
References: Lf.S. EPA.  Draft. Mining Waste Releases and Environmental Effects Summary
for the State of South Dakota. March 1994.

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South Dakota
                         Homestake Gold Mine:
 Heavy  Rains Force Homestake to Correct Drainage Problems
  Sectors: Gold and silver

  Facility:  Homestake Gold Mine, Homestake Mining Company (HMC), Lead, SD

  Facility Overview: HMC was engaged in gold mining, milling, and vat leaching
  operations as well as open pit and underground mining for precious metal ore.
Waste
Strea
m(s):
Waste
water
treatm
ent
plant
liquids.
Waste Management Practices: Mine water and tailings from the mill flowed into the facility's
Grizzly Gulch tailings pond.  HMC pumped water from the pond to its wastewater treatment
plant.  The plant used innovative biological treatment to remove metals and cyanide.  Treated
tailing waters were discharged into Gold Run Creek.

Type of Impact/Media Affected: Heavy rainfall in May 1988 caused run-off from the area
above Blacktail dump to overrun the drainage ditch and flow across the 5,000-foot waste bench
and down the face of Blacktail dump.  As a result, a deep gully formed in the face of the
Blacktail dump.  The drainage problem was corrected by regrading and compacting the area of
the waste bench that was affected. In 1988, a cyanide spill was caused by an overflowing
pump  station near Grizzly Gulch.

Regulatory Action/Response: The South Dakota Department of Water and Natural
Resources prepared a Memorandum to File, dated November 18, 1988, thafdescribes a
cyanide spill at the Homestake Facility. The memorandum indicated that emergency spill
overflow structures being installed at the site would prevent any future spills from leaving HMC's
property.

A/o comments were received on this comment summary.

References: U.S. EPA. Draft. Mining Waste Releases and Environmental Effects Summary
for the State of South Dakota. March 1994.

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                    South Dakota
Page 143

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Texas
                                El Paso Plant:
             Run-off and Discharge Pollute Rio Grande
   Sectors: Copper, lead, and zinc

   Facility: ASARCO, El Paso, TX

   Facility Overview: This smelting plant, which had operated since 1887, was used for the
   recovery of zinc, copper, and lead for production of copper anodes, lead bullion, and zinc
   oxide.
Waste Stream(s): Copper, zinc, and lead slag.

Waste Management Practices: Waste smelter slag had historically been deposited on-site.
According to ASARCO, the facility ceased producing zinc slag in early 1982 and lead slag in
1985. Many of the present structures were built on old waste slag deposits. Slag from the zinc
fuming furnace and copper reverb process was stored on-site and removed by a contractor,
who crushed it and sold the material for railroad bedding or sandblasting abrasives.  Lead slag
was stored on-site until it became economically viable to recycle and refine this material for zinc
recovery.

      Waste piles had been built on slag deposits of unknown permeability.  In general, the
waste piles had received smelting slag from the zinc, copper, and lead processes, fire assay
crucibles, used kiln brick, iron scrap, and pond dredgings.

Type of Impact/Media Affected: Samples from stormwater run-off taken in 1981 and 1982
showed  that primary and secondary drinking water levels were exceeded for arsenic, cadmium,
chromium, copper, lead, manganese, mercury, silver, and zinc. Samples from the southern
edge of the slag deposits that were taken in July 1981 and September and December 1982
showed  ranges of total concentrations of metals as follows: arsenic, 0.84 to 11.6 mg/L;
cadmium, 2.05 -12.0 mg/L; chromium, 0.04 - 0.31 mg/L; copper, 16-240 mg/L; lead, 28 - 220
mg/L; manganese, 2.3 -12.0 mg/L; mercury, 0.046 - 0.160 mg/L; and zinc, 21-102  mg/L.
Silver was detected at 1.28 mg/L. In addition, EP toxicity criteria were exceeded for  lead,
cadmium, and arsenic. In 1984, the Texas Department of Water Resources concluded that
ASARCO was in violation of Texas regulations prohibiting discharge of hazardous metals to
inland waters (TDWR Permanent Rules 156.19.002).

Regulatory Action/Response: An Industrial Solid Waste Compliance Monitoring Inspection,
conducted in 1985 by the Texas Department of Water Resources, noted that stormwaters from
the slag  landfills and from the plant, which had received much slag fill, had high levels of heavy
metals and had discharged into the American Canal and the Rio Grande River.

      In 1986, a Solid Waste Compliance  Monitoring Inspection Report was completed by the
Texas Water Commission.  A comparison of the concentrations upstream and downstream of
the facility found elevated concentrations of arsenic, lead, cadmium, and copper in Rio Grande

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                                                                          Texas
sediments near the ASARCO facility.  For example, lead was detected at 7.0 mg/L upstream,
62 mg/L at the ASARCO facility, and 24 mg/L downstream.

      According to the Texas Water Commission, the primary problems at this site had
evolved  from surface run-off from slag piles. According to ASARCO, the TWC Superfund Unit
determined in June, 1987, that improvements at the facility, such as diverting surface run-off to
a central retention area for sampling before discharge and constructing a lined storm water
pond, had resulted in no  impact on surface water and in the company achieving compliance
with the  Texas Water Code.

Comments were received to this damage summary.  See Appendix A for comment listing and
Agency response.

References:  U.S. EPA.  Report to Congress on Special Wastes from Mineral Processing
Facilities. Volume II: Methods and Analyses. July 1990.

ASARCO. Comments to  Phase IV Proposed Rule on Land Disposal Restriction to Mineral
Processing Wastes. 1996.

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Utah
         Kennecott North:  Tailings from 5,700 Acre Pond
                           Pollute Ground Water
   Sector: Copper

   Facility: Kennecott Copper Corporation, Magna, UT

   Facility Overview: Kennecott operated a wide variety of mineral processing and
   production facilities in the area since around 1900. The primary metal produced was
Waste Stream(s): Tailings.

Waste Management Practices: The site contained a 5,700 acre tailings pond, a slag pile, and
a refinery evaporation pond.

Type of Impact/Media Affected:  Analysis of ground water monitoring wells found high levels
of arsenic and selenium. The principal aquifer, which supplied water to the Magna municipal
water system, underlaid many of the sources at the site. In addition, surface water analysis
near wetlands showed releases of copper to the ditch near the large tailings pond. Residential
soils in the town of Magna have also been contaminated by tailings from the site.
Contaminants of concern include arsenic, chromium, copper, lead, selenium, and zinc.

Regulatory Action/Response: To prevent expiration of the statue of limitations, the State of
Utah filed a Notice of Claim on July 31, 1986 for Natural Resource Damages under section 107
of CERCLA in the amount of $129 million. The state followed the claim with a lawsuit for
ground water damage. During this time, Kennecott was conducting a hydrogeologic study,
which continued following the court granted motion to stay for all legal proceedings.  In 1991,
the state and Kennecott negotiated a $11.7 million settlement for damages. A proposed
Consent Decree for this settlement was denied by the court in 1992.

      The site was proposed to be added to the NPL in 1994.  Currently,  Kennecott has a
MOU with EPA regarding remedial actions and is not listed on the NPL.  Kennecott has been
conducting an investigation in the area near the smelter to determine the nature and the extent
of contamination prior to construction of a new smelter.

Comments were received to this damage summary. See Appendix A for comment listing and
Agency response.

References: U.S. EPA.  Draft. Mining Sites on the NPL August 1995.

801 F. Suppl 553.  The State of Utah v. Kennecott Corporation, Civ. No. 86-C-0902G, United
States District Court, D. Utah, C.D. September 3,1992.

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                                                                           Utah
Kennecott. Comments to Phase IV Proposed Rule on Land Disposal Restriction to Mineral
Processing Wastes. 1996.
                                     Paae 147

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Utah

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                                                                           Utah
     Kennecott South:  Drinking Water Wells Contaminated
                              by Leach Dumps
   Sector: Copper

   Facility: Kennecott Copper Corporation, Copperton, UT

   Facility Overview: Mining in the area began in the 1860's, with copper being the primary
   metal produced. Various mining companies have operated in the district over the years,
   including Anaconda Co. and Kennecott Copper Corp.
Waste Stream(s):  Tailings and leachate from the 5,350 acres of leach dumps.

Waste Management Practices:  Kennecott sent much of its mineral processing waste and
copper ore from this site to the North Zone.  Tailings produced in the South Zone was shipped
to the North Zone by rail, or collected in the waste dumps.

Type of Impact/Media Affected: Ground water contaminants of concern originating from the
waste dumps have included arsenic, cadmium, chromium, copper, lead, nickel, selenium, silver,
and zinc.  Concentrations of arsenic and cadmium were found in two municipal wells and one
domestic drinking water well.  A large sulfate plume that originated from the large Bingham
Reservoir extended for miles in the Salt Lake Valley principal aquifer.  Communities were
precluded from using water from this area.  Soil was contaminated with tailings in residential
areas within the city of West Jordan.

Regulatory Action/Response: The site was proposed to be added to the NPL in 1994.
Currently, Kennecott has a MOU with EPA regarding remedial actions and is not listed on the
NPL.  Kennecott has participated in cleanup work under EPA enforcement orders.

Comments were received to this damage summary. See Appendix A for comment listing and
Agency response.

References:  U.S.  EPA.  Draft.  Mining Sites on the NPL. August 1995.

Kennecott. Comments to Phase IV Proposed Rule on Land Disposal Restriction to Mineral
Processing Wastes. 1996.
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Utah
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                                                                               Utah
                                Monticeilo  Mill:
            Mill Tailings Contaminate  Nearby Community
   Sectors:  Uranium and vanadium

   Facility:  Monticeilo Mill, San Juan County, UT

   Facility Overview:  The mill began vanadium production and uranium-vanadium sludge
   production in 1942 and 1943, respectively. Vanadium minerals were converted to soluble
   form using a salt-roast process.  The addition of pyrite and sulfuric acid eventually led to
   the precipitation of vanadium pentoxide. From 1948 to 1960, a uranium mill operated
   using a variety of processes including raw ore carbonate leach, low-temperature roast/hot
   carbonate leach, salt roast/hot carbonate leach, acid leach-Resin-in-Pulp (RIP) and raw or
   carbonate leach, and a carbonate pressure leach RIP.
Waste Stream(s):  Uranium and vanadium mill tailings.

Waste Management Practices: The site consisted of four tailings impoundments. Two
tailings impoundments, the Vanadium Pile and the Carbonate Pile, received waste prior to the
1955 installation of the acid leach RIP plant. The Carbonate Pile received tailings from the salt
roast/hot carbonate leach milling process. The milling process responsible for the tailings in the
Vanadium Pile was unknown, though both piles may have been used simultaneously. In 1955
and 1956, the Acid Tailings Pile received waste from both the carbonate-leach plants and the
acid leach-RIP.  Tailings from the acid leach process were combined with carbonate plant
tailings and calcium hydroxide for neutralization and then pumped to the Acid Pile, where a
portion of pond overflow was recycled through the leach circuit.  The remaining overflow was
discharged to Montezuma Creek. To prevent seepage and reduce discharges into the creek, a
six-inch liner of compacted bentonite was used to construct the Acid Pile, and tailings pond
effluent was partially recycled. The fourth impoundment (East Pile) received tailings from 1956
to 1960. Having processed nearly one million tons of uranium ore at the mill, the total volume
of the resulting tailings and tailings-contaminated soil was estimated to be 1.5 million cubic
yards.

Type of Impact/Media Affected: A baseline risk assessment revealed that the radiologic
health threat was attributed predominantly to uranium and radium-226. Uranium posed  an
additional health concern due to its toxicity.

       Dispersion of the uranium mill tailings from the mill site occurred through natural  and
man-caused activity. Wind and surface water dispersion had spread the tailings to peripheral
properties, while the use of tailings as a construction material had distributed the tailings to local
residential and commercial properties.  Two hundred acres of peripheral properties north,
south, and east of the mill site contained  elevated levels of radium (radium was used as a proxy
for uranium, radium 226, arsenic, cadmium,  chromium, copper, lead, molybdenum, vanadium,
and zinc).
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Utah
Regulatory Action/Response: The U.S. Department of Energy, under the Atomic Energy Act,
initiated the Surplus Facilities Management Program (SFMP) in 1978 to assure safe caretaking
and decommissioning of government facilities that had been retired from service but still had
radioactive contamination. The Monticello Mill site was listed on the NPL in. November 1989.
The Superfund Amendments and Reauthorization Act of 1986 (SARA) placed the SFMP
activities under the regulatory framework of CERCLA.  The DOE, EPA, and the State of Utah
entered into a Federal Facility Agreement (FFA) pursuant to CERCLA Section 120 in December
1988, that stipulates the procedural framework for developing and implementing response
action under CERCLA/SARA.

A/o comments were received on this comment summary.

References:  U.S. EPA.  Draft Final. Mining Sites on the National Priorities List:  NPL Site
Summary Reports. Volume  III. June 21, 1991.
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                                                                          Virginia
                                 U.S. Titanium:
                Contaminated Titanium Mine Kills Fish
   Sector:  Titanium

   Facility: U.S. Titanium Superfund Site, Piney River, Nelson County, VA

   Facility Overview:  Operations began in 1931 and included the production of titanium
   dioxide pigment from native ilmenite ore using the sulfate process, as well as the
   production of phosphate through the digestion of native apatite ore with sulfuric acid.
   Phosphate production was halted in 1944.
Waste Stream(s): Spent sulfuric acid, hydrated ferrous sulfate (copperas), diatomaceous
earth filter cake, gypsum, and unreacted apatite and titanium ore.

Waste Management Practices: The production of titanium dioxide pigment and phosphate
began in 1931 under the ownership of the Virginia Chemical Corporation. From 1931 to 1944,
the waste streams were discharged directly into the Piney River. American Cyanamid
Company purchased the site in 1944, focusing on titanium dioxide production only.  Waste
streams continued to be discharged directly into the river until 1947, when the company
constructed a state-permitted settling pond to remove settleable solids from the wastewater.  In
the early 1950s, the company employed partial neutralization of the wastewater, which
eliminated suspended solids from the effluent and significantly reduced sulfuric acid discharges
by 1955.  The company then installed a neutralization lagoon where wastewater was treated to
a pH of at least five, flow and pH equipment monitored the effluent; and a sulfuric acid recovery
plant operated continuously. In  1976, the U.S. Titanium Corporation purchased the site, but
failed to operate and maintain the leachate-collection and recirculation system.

Type of Impact/Media Affected: The surface water, ground water, and soil had all been
contaminated and were characterized by low pH.  Problems were associated with acidified soils
throughout the site and buried copperas.  Elevated metal levels and acidity in the Piney River
had led to a decline in the number and  diversity of the fish population.  Between 1977 and
1981, run-off from the site resulted in six fish kills that resulted in more than 220,000 dead fish.

Regulatory Action/Response:  In 1977, the Virginia State Water Control Board (SWCB)
ordered U.S. Titanium to pay for the fish kill and submit a plan to dispose of the waste
copperas.  Although the company paid  for the fish, it did not provide the requested disposal
plan. After a serious fish  kill in 1979, SWCB requested that the Circuit Court of Nelson County
order the company to bury the copperas by December 31, 1980. After several  site inspections
and assessments by EPA, the site was listed on the NPL in September 1983.  Following a civil
action by the Commonwealth of Virginia, American Cyanamid was found liable for damages
caused by the site. The company signed a stipulation and order with the Commonwealth
establishing a schedule for completing a temporary source control  action, and a Supplemental
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Virginia
Remedial Investigation and Feasibility Study for the site. A Record of Decision was signed by
the Region 3 Administrator and concurred by the Commonwealth of Virginia in November 1989.

No comments were received on this comment summary.

References:  U.S. EPA. Mining Sites on the National Priorities List: NPL Site Summary
Reports, Volume V. 1991.
                                       Page 154

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                                                                  Washington
                       ASARCO Tacoma Smelter:
               Copper Slag Contributes to Bay Impacts
   Sector: Copper

   Facility: ASARCO, Commencement Bay/Nearshore Tideflats, Tacoma, WA

   Facility Overview: The ASARCO Tacoma Smelter operated from 1890 until  1986.
   Originally a primary lead smelter, the facility had converted to a copper smelter by 1911.
   The facility specialized in processing high arsenic ores.
Waste Stream(s): Slag from primary copper smelting.

Waste Management Practices: Slag produced by the smelter was sold as rip-rap, ornamental
rock, and road ballast; used as on-site fill material; and was deposited on the water's edge,
extending the property 450 feet into Commencement Bay.  Also, slag deposits have formed a
2,000-foot peninsula to the northwest of the ASARCO site, which reportedly are used as habitat
by marine organisms.  When the facility was operating, ASARCO used baghouses, electrostatic
precipitators, and cyclones to control air emissions.

      From 1971 to 1973, baghouse dust, paper, asphalt-coated paper, and off-spec mineral
fiber were disposed of in the 2.6 acre U.S. Gypsum landfill. Between 1978 and 1982, the B&L
Wood Waste Landfill site was used for the disposal of soil and wood debris collected from
several nearby log sort yards, which received slag as ballast material.

      The smelter Record of Decision (ROD) calls for removing soils that contain hazardous
wastes and that are contaminating ground water.  Remaining soils and slag will be capped.
Surface water drainage features will be re-established. The shoreline adjacent to the facility will
be protected from erosion as appropriate to prevent contaminant migration.

Type of Impact/Media Affected:  Sampling begun in  1983 identified heavy metals such as
arsenic, zinc, copper, lead, nickel,  antimony, and cadmium in soils. Approximately 950 acres of
nearby residential areas have been contaminated by the smelter.  In addition to soil
contamination associated directly with the smelter complex, contamination extends to surface
water, ground water, and sediments in adjacent areas.

Regulatory Action/Response: The Commencement Bay Nearshore/Tideflats site was added
to the NPL in September 1983.  From November 1983 to June 1984, the Washington
Department of Ecology, Water Quality Investigation Section (WQIS) conducted a remedial
investigation to characterize surface water and sediment contamination from  12 log storage and
sorting facilities ("sort yards") in the Tideflats area that had received ASARCO's slag as ballast
material. WQIS determined that the use of ASARCO slag for ballast at the log sort yards is the
likely cause  of elevated metals concentrations seen in log sort yard run-off, nearshore  surface
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Washington
waters, and sediments.  According to Asarco, any contribution of contaminants by slag has
been found to be minimal.

       EPA conducted a remedial investigation between 1984 and 1985 which found significant
detections of pollutants in the Hylebos Waterway sediment, and 35 to 50 percent fewer species
existing in the Hylebos Waterway than in adjacent habitats. Asarco cites studies that reveal
that slag as the habitat of choice of marine organisms.  During 1986 and 1987, EPA conducted
site inspections of four log sorts yards and one wood waste landfill in the Nearshore/Tideflats.
Ground water samples from 15 of the 19 wells exceeded one or more drinking water standards,
maximum  contaminant levels, or water quality criteria identified for arsenic, copper, lead, and
zinc. Asarco reports that elevated metal runoff from the log yards resulted from combining slag
with woodwaste, subjecting the mixture to heavy equipment. The log yards were remediated
under CERCLA and State Superfund laws.

       In 1985 and 1986, researchers from the University of Washington found children under
the age of six living within a half mile of the smelter to have high median urinary arsenic
concentrations of 48 ug/L for boys and 24.5 ug/L for girls.  Ten percent of the entire study
population, children and adults, in North Tacoma, Vashon Island, and Maury Island had arsenic
concentrations greater than 50 ug/L, and 3 percent had concentrations greater than 100 ug/L.

       Reportedly, a study was conducted by the Tacoma-Pierce County Health Department
after the smelter closed.  The study reportedly found that the urinary arsenic levels of children
aged 2 to 17 living near the smelter were well below the urinary arsenic levels measured by the
University  of Washington. The median value was reported to be 10.9 g/L for males and 6.4 g/L
for females.

Comments were received to this damage summary.  See Appendix A for comment listing and
Agency response.

References:
U.S. EPA.  Draft Final. Mining Sites  on the National Priorities List: NPL Site Summary Reports.
Volume II.  June 21, 1991.

U.S. EPA.  Report to Congress on Special Wastes from Mineral Processing.  Technical
Background Document:  Damage Case Investigation. July 1990.

Ceto, Nick (EPA Region 10). Written Correspondence Concerning Commencement Bay to
Bruce Rappaport,  ICF Incorporated.  December 4, 1995.

ASARCO.  Comments to Phase IV Proposed Rule on Land Disposal Restriction to Mineral
Processing Wastes.  1996.
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                          CHAPTER 3.  REPORT FINDINGS
        The U.S. EPA Environmental Protection Agency (EPA) developed this background document to
illustrate the types and magnitude of human health and environmental damages caused by wastes from
mining (i.e.. extraction and beneficiation) and mineral processing, particularly damages caused by
placement of such wastes in land-based units. These damage cases provide convincing evidence that
wastes from extraction, beneficiation, and processing of metals and other minerals have caused
significant human health and environmental damages. Both wastes that are subject to and, under the
Bevill Amendment (RCRA §3001(b)(3)(A)(I-iii), exempt from regulation as hazardous wastes under
Subtitle C of the Resource Conservation and Recovery Act (RCRA) are responsible for these damages.
These damages occurred across the broad range of mineral sectors, including virtually all of the sectors
significantly affected by the proposed supplemental rule. In addition, these damages have occurred
throughout all regions of the United States, in a wide variety of climatic and geological zones and in both
rural and urban areas.

       The depth and breadth of damages caused by wastes from mining and mineral processing
illustrated by the cases and the background sources identified in this document provide technical support
for various provisions of the supplemental proposed rule to apply Phase IV land disposal  restrictions to
newly identified mineral processing wastes and make other regulatory changes. These damage cases, for
example, support the proposed provisions to impose waste management conditions on the exclusion from
the definition of solid wastes of certain secondary materials from the primary mineral processing
industry because of the human health and environmental risks presented by such materials.  The damage
cases help justify these conditions, particularly the requirements for basic unit integrity, by illustrating
damages that may occur without such protection, including surface water, groundwater, and soil
contamination.  See, for example, East Helena Smelter, Montana; Martin  Marietta Reduction Facility,
Oregon; Palmerton Zinc, Pennsylvania; and U.S. Titanium, Virginia.

       The damage cases also support the proposed application of the "mixture rule" (and other standard
Subtitle C requirements) to hazardous wastes that are disposed, stored, mixed, or otherwise combined
with Bevill-exempt solid wastes.  See, for example, ASARCO Globe Paint and Smeltertown, Colorado;
and Anaconda Smelting and U.S. Antimony, Montana.  The cases include instances of damage caused by
Bevill-exempt wastes, including health risks from direct contact and ingestion when the exempt wastes
have been used  as soil supplements, fill materials, and for landscaping purposes.
                                           Page 157

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                                                                         Appendix  A
  COMMENTS AND RESPONSES ADDRESSING DAMAGE CASES INACCURACIES
                               FOR FACILITIES IN THE
        1996 HUMAN HEALTH AND ENVIRONMENTAL DAMAGES REPORT
The Agency received a considerable number of comments on the cases presented in this report.
The report has incorporated design and operation information supplied by the commenters and
has also amended the report to reflect cases where remedial actions were not fully reflected in the
text. The Agency does not necessarily agree with commenters position that their individual
responses have effectively addressed contamination. That can only be determined from field
monitoring data.

Commenters objected to the way the Agency characterized specific waste streams.
Characterizations of waste streams in this report do not constitute a regulatory determination,
rather the Agency used terminology found in state files.

Comments by ASARCO (COMM 36) regarding the Ray Mines Complex in Arizona:

The commenter indicated that the 1996 damages summary for the Hayden Smelter, which is part of the
ASARCO Ray Complex in Arizona, is deficient in several key respects, including the following:

•       The description regarding the lined pond at Hayden is erroneous because  acid plant blowdown
       was not sent to this pond. Instead, acid plant blowdown was neutralized in the wastewater
       treatment plant and the solids (calcium sulfate wastewater treatment plant sludge) were sent to
       the lined impoundment.  This sludge is one of the twenty mineral processing wastes that remain
       excluded by the Bevill Amendment.  See 40 C.F.R. 261.4(b)(7)(viii). EPA's extensive Bevill
       Amendment study of the management of this sludge showed no damage or threat of damage to
       human health and the environment. Historically, very little calcium sulfate sludge was mined
       from the impoundment and reprocessed in the smelter, and such remining has not occurred for
       years. Only a ten to fifteen gallon per minute bleed stream of brine concentrator flow (pH 6 to 7)
       was discharged directly to the lined impoundment. This practice ceased in 1991.

       Response: The Damage Summary was revised to include the information regarding the
       destination of the acid plant blowdown and the cessation of brine concentrator discharge.

•       Additionally, the underground storage tanks containing gasoline and diesel fuel have been
       removed and replaced with above-ground storage tanks. The gasoline contamination has been
       completely remediated, and the diesel fuel remediation  is almost finished. The PCB and sulfuric
       acid spills have long since been completely remediated  in accordance with applicable law.
       Neither EPA nor the State of Arizona initiated any enforcement action regarding these releases.
       Since 1992, the Asarco Hayden smelter has been free of transformers and any other equipment
       containing PCBs.

       Response: The Damage Summary was updated to include the information regarding the USTs
       and the other remediation efforts.
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            iy A
       Statements in the Arizona 1994 Mining Waste Release document regarding Hayden plant's air
       emissions were not relevant to the Phase IV LDR rulemaking.  The commenter also reported
       misrepresentations in the 1994 Mining Waste Release Document ofexceedances of the National
       Ambient Air Quality Standards.

       Response: This comment addresses possible inaccuracies in the 1994 Mining Waste Releases
       and Environmental Effects Summary for the State of Arizona; the comment does not address
       any inaccuracy in the data summarized in this report.  As no inaccuracies addressing the case
       summary were reported by the commenter, no changes were made to the damage summary.

       The instances of alleged damage provide no basis of support for EPA's present rulemaking
       proposal on mineral processing wastes.  Furthermore the damages are from historical practices.

       Response: This specific comment addresses a policy interpretation. As no inaccuracies
       addressing the case summary were reported by the commenter, no changes were made to the
       damage summary.
Comments by ASARCO (COMM 36) regarding the East Helena Smelter in Montana:

The commenter had two comments related to the 1996 Human Health and Environmental Damages
document:

•      While EPA correctly identifies primary and fugitive emissions and process ponds as the sources
       of contamination at the East Helena plant, the Agency incorrectly assesses an impact on human
       health from these sources.  Blood lead testing of children in the community was conducted in
       response to process air emissions (i.e., not RCRA waste management), which cannot be
       addressed in this rulemaking.

       Response: This comment addresses a policy interpretation. As no inaccuracies addressing the
       damage case summary were reported by the commenter, no changes were made to the damage
       summary.

•      Process waters have not contributed to elevated blood lead levels or to any other health-related
       problems.  Further, implementation of the Record of Decision for process ponds is having a
       positive impact on ground water quality.

       Response: EPA did not intend to state there was a direct connection between process water
       releases and the decision to test or to the test results themselves. The Damage Summary was
       amended to show Asarco 's claim regarding the blood lead testing;

•      The implementation of the Record of Decision for process ponds is having a  positive impact on
       groundwater quality.

       Response: The Damage Summary was updated to include this information;
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Comments by ASARCO (COMM36) regarding the Globe site in Colorado:

The commenter indicated that while EPA has identified slag and process wastewater as the trvvo primary
wastestreams at this site, it has failed to recognize that slag has not contributed to the environmental
concerns at the site. Also, the commenter found EPA's characterization of the historic management of
process wastewaters inaccurately reflects current practices at the site. Hence, this information should not
be used as a basis for the Supplemental Proposed Rule. The commenter added that the actions taken at
site to date, under State Consent Decree, are more extensive than identified by EPA.  Finally, the
commenter mentioned that the local housing project was not closed due to the Globe Plant; rather a
number of other reasons were involved, including financial resources, age and condition of the facility.
proximity to an interstate highway and expansion project, and occupancy issues.

       Response: The Damage Summary was updated to acknowledge ASARCO's opinions regarding
       the absence of slag-related environmental concern as well as the other factors involved in the
       closing of the housing project.

The commenter also reported the following: Two seasons of community soils remediation have been
completed, a medical monitoring program has been implemented and the Industrial Drainage Ditch has
been remediated. Also, plant site soils with elevated concentrations of lead, cadmium and arsenic have
been capped and the interceptor trench has been backfilled.

       Response: The Damage Summary was revised to discuss the remediation efforts; the Agency,
       however, has not verified the information reported by the company.
Comments by ASARCO (COMM 36) regarding the Glover Smelter in Missouri:

The commenter claimed that the 1996 Human Health and Environmental Damages includes a number of
inaccuracies regarding the location of the Asarco Glover smelter. It is not located within the Mark
Twain National Forest and is not in an area known as the "Old Lead Belt." The plant is, however,
located in the "New Lead Belt" of Missouri.

       Response: The Damage Summary was updated to incorporate this information, however, the
       Agency has not verified the information reported by the company.

The commenter further noted that, in 1994, Asarco and MDNR entered into a Consent Decree that
requires, among other activities, a  Site Assessment and Investigation to determine the nature and extent
of certain contamination at the site. The Site Assessment has not yet been completed. It is not possible
to determine whether the slag will  be identified as a source of surface or groundwater contamination until
after the Site Assessment has been completed.

       Response: The Damage Summary was updated to incorporate this information, however, the
       Agency has not verified the information reported by the company.
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Appendix A
Comments by ASARCO (COMM 36) regarding the ASARCO Zinc Smelter in Columbus, Ohio:

The commenter made the following remarks:

•      Asarco operated the Columbus plant as a zinc oxide smelter from 1971 through 1986; the
       reference in the 1996 Human Health and Environmental Damages document identifying this site
       as a mine site is incorrect.

       Response: The Damage Summary has been revised to identify the site as a "smelter", rather
       than as a "mine."

•      EPA also states that approximately 38,000 tons of zinc slag had been stored on site on 50 acres
       of property.  This is incorrect since the entire site is only approximately 50 acres and it is not
       covered with slag.  In 1990, Asarco estimated at least  50,000 tons of slag were distributed
       throughout the site, after shipping approximately 40,000 tons off site in 1987. (The 1996 Human
       Health and Environmental Damages document refers to 35,000 tons being shipped off site.)

       Response: The Damage Summary has been revised to include ASARCO's estimations of slag
       distribution and shipment; the Agency, however,  has not verified the information reported by
       the company.

•      EPA's information is also outdated with regard to surface water quality data.  While Asarco
       continues to treat storm water at the water treatment plant it constructed in 1984 and upgraded in
       1990, the Ohio EPA has conducted several bioassay since 1988 on effluent from the plant.
       Results generally show that the discharge is acutely toxic to Ceriodaphnia but not to fathead
       minnows. Bioassay typically pass for both Ceriodaphnia and fathead minnows for tests that
       utilize water from Alum Creek.

       Response: The Damage Summary has been revised to include Ohio EPA's bioassay results
       regarding water from Alum  Creek as reported by ASARCO;

•      EPA's focus at the Columbus site is on zinc slag, which is a Bevill material and outside the scope
       of RCRA Subtitle C controls. Also, the  surface water  issues identified in the report were caused
       by historic conditions and would not be  addressed or affected by EPA's Supplemental Proposed
       Rule. Finally, Asarco's voluntary actions to address any surface water concerns are being
       performed with oversight and cooperation of State and local agencies. Therefore, the
       information in the record related to the Columbus site  does not support the Agency's efforts to
       regulate secondary materials that are managed in land-based units.

       Response: These comments  address historical practices and policy interpretation. As no
       inaccuracy in the Damage Summary has been reported by the commenter, no change has been
       made to the Damage Summary.
Comments by ASARCO (COMM 36) regarding the ASARCO El Paso Plant in Texas:
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                                                                          Appendix A
The commenter submitted the following remarks:

•      The Asarco El Paso plant, which has been in operation since 1887 (not 1883. as indicated in the
       1996 Human Health and Environmental Damages document), ceased producing zinc slag in early
       1982 and lead slag in  1985.

       Response: The Damage Case has been revised to include Asarco's information showing that
       the facility began operating in 1887 and ceased generating zinc slag in early 1982 and lead
       slag in 1985;

•      EPA summary is outdated and fails to recognize that much of the surface and storm water
       concerns relate to historical management practices.  More importantly, due to the diversion of
       surface run-off to prevent storm water from leaving the site and the construction of a lined storm
       water pond, recent samples demonstrate there is no impact on surface water caused by the El
       Paso plant.  Therefore, while historical practices may have caused some elevations in metals
       concentrations in surface water, these concerns have been addressed and current management
       practices are not affecting surface water.

       Response: The Damage Summary has been revised to include that current management
       practices do not have an impact on surface water quality;

•      In addition, El Paso does not utilize "settling" ponds as referenced by EPA.

       Response: The Damage Summary has been revised to remove any reference to "settling
       ponds,"
Comments by ASARCO (COMM 36) regarding the ASARCO Tacoma Smelter in Washington:

The commenter made the following points:

•      Copper reverberatory slag was a major byproduct of the Asarco Tacoma plant. The slag was
       used as fill material and also sold for a variety of other uses. Contrary to the suggestion made by
       EPA in the 1996 Human Health and Environmental Damages document, any contribution of
       contaminants to Commencement Bay by slag has been found to be minimal. Studies have shown
       that slag is the habitat of choice of marine organisms.

       Response: The Damage Summary has been revised to acknowledge the habitat studies. The
       Summary was also revised to incorporate Asarco's claim that the impact of the slag was
       minimal;

•      A problem did arise when slag was combined with woodwaste and subjected to heavy
       equipment.  This combination resulted in elevated metal runoff from area logyards. The
       logyards have now been remediated under CERCLA and state Superfund laws. As with other
                                          Page 163

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Appendix  A
       Asarco sites, historical environmental concerns at the Tacoma smelter have been addressed
       under the CERCLA program and remediation is underway.

       Response: The Damage Summary was revised to include this information; the Agency,
       however, has not verified the information reported by the company.

       The University of Washington study referenced by EPA collected most of its data when the
       Tacoma smelter was still operating.  After the smelter closed, the Tacoma-Pierce County Health
       Department conducted a follow-up urinary arsenic study of area children. That study
       demonstrated that the urinary arsenic levels of children aged 2 to 7 living near the Tacoma
       smelter were well below the urinary arsenic levels measured by the University of Washington.
       The median value for males was 10.9 g/L and for females was 6.4 g/L. There is no evidence
       that slag contributed in any way to these urinary arsenic values.

       Response: The Damage Summary was revised to include the results of the studies conducted
       by the Tacoma-Pierce County Health Department.

       The Supplemental Proposed Rule would not address any alleged damages to human health or the
       environment from this site since slag is exempt under the Bevill Amendment.

       Response: This specific comment addresses a policy interpretation. As no inaccuracies in the
       Damage Summary were reported by the commenter, no change were made to the damage
       summary.  The Agency points out that damages from extraction and beneficiation, also
       exempt under the Bevill amendment, are included in this document.
Comments by Cyprus Amax (COMM46) regarding the Climax Mine in Colorado:

The commenter took exception to describing the Climax Mine (as shown in Exhibit 3) as "inactive."
While the mine is not currently operating, its status is accurately described as "on standby".  Significant
mineralized reserves remain such that it is likely that it will operate in the future. Certainly,  it is not
"inactive" in the same sense as the other sites in the exhibit which are so categorized.

       Response: Exhibit 3 was revised to show the status of the Climax mine as "standby."

The commenter also pointed out that the damage cited at Climax Mine is an air quality issue which
occurred in 1986 and which was solved long ago. The issue was handled under authorities of the
Colorado Department of Health and Mined Land Reclamation Division. Had the proposed rule been in
effect in 1986, it would not have had any impact on the constituents of the tailings.  Also, the event
described resulted in no known human health or environmental damages contrary to EPA's implied
allegation.

       Response: This specific comment addresses a policy interpretation.  As no inaccuracies
       addressing the case summary were reported by the commenter, no changes were made to the
       damage summary.
                                          Page 164

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                                                                           AppendiY A
Comments by Cyprus Amax (COMM46) regarding the URAD Mine and Mill in Colorado:

The commenter reported the following:  "The description of the alleged human health and
environmental damages at the Urad site in 1996 Human Health and Environmental Damages document is
grossly misstated. Tailings have not and are not entering the creek as EPA implies.  Urad experienced
difficulties in meeting water standards from footing drains in tailing embankments, which it solved by
constructing a waste water treatment plant and making other water management changes. The NPDES-
permitted discharges are now meeting water quality standards.  The water discharge is a combination of
collected and treated runoff through the historic Urad mine area as well as water from the active
Henderson underground mine. The cited issue was resolved under existing Clean Water Act regulations
and continues to be regulated under the Clean Water Ac

       Response: Although the Damage Summary reports that "discharge from the tailings areas"
       was the source of contamination,  the summary did not state or imply that tailings themselves
       entered the surface water.  The commenter concedes that Urad had encountered problems
       with the footing drains in the tailing embankments. The title of the Damage Summary has
       been revised to show that the source of contamination was the "tailings drainage."
Comments by Cyprus Amax (COMM46) regarding the Tar Creek/Oklahoma/Cherokee
County/Kansas site:

The commenter reported that the "Tri-State Mining District, which also includes Jasper County, Missouri
is a historic mining area.  Most extraction and beneficiation activities in the area occurred from the mid-
1800's through the 1940s.  Some smelting also occurred in the area. The alleged environmental
contamination in these areas is the result of the extraction and beneficiation activities, or air deposition
of metals from smelters in the area. These sites, therefore, provide no support for EPA's allegations that
the secondary materials EPA is seeking to regulate under this proposal caused or were related to the
alleged environmental contamination."

       Response: This specific comment addresses a policy interpretation.  As no inaccuracies
       addressing the damage case summary were reported by the commenter, no changes were made
       to the damage summary.
Comments by Cyprus Amax (COMM46) regarding the Foote Mineral Company in Pennsylvania:

Cyprus Foote Mineral Company, a subsidiary of Cyprus Amax, reported that they excavated and
bioremediated soil at the site which was contaminated by hydrocarbons (i.e. diesel fuel) from a
previously undetected plant site underground fuel delivery line and railhead. The report erroneously
implies that this work had something to do with mineral processing that the  proposed rule could have
prevented. Also, contrary to the statement made in the damage summary that the "waste streams," in
                                          Page 165

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Appendix A
question at the site are ''process wastes," the source of the lithium and other constituents in the various
media are unknown.

       Response: The Damage Summary was revised to incorporate the lithium source comments;
       the Agency, however,  has not verified the information reported by the company.  The
       remaining portion of the comment addresses a policy interpretation.  As no inaccuracies
       addressing the Damage summary were reported by the commenter, no further changes were
       made.
Comments by Cyprus Amax (COMM46) regarding the Miami Mine in Arizona:

The commenter took exception to information reported one of the Attachments to the 1996 damage
summaries addressing alleged releases from the Cyprus Miami Mine. All of the "spill" incidents
identified in this attachment deal exclusively with water issues entirely regulated by the Clean Water Act
and, more recently, the Arizona Aquifer Protection Permit("APP") program. The Miami Mine adopted a
stringent stormwater management plan and has made substantial investments in new facilities, all in an
effort to avoid the kinds of incidents discussed in the attachment (incidents which occurred more than
five years ago). The proposed Supplemental Phase IV LDR rule has no relationship to these alleged
"releases."

       Response: While EPA appreciates the additional information, this document includes no
       damage summary for this facility (the specific comment refers to an attachment in which
       several wastestreams were listed); as no inaccuracies addressing the case summary were
       reported by the commenter, no changes were made to the damage summary.
Comments by Cyprus Amax (COMM46) regarding the Sierrita Mine and Mill in Arizona:

The commenter took exception to information reported one of the Attachments to the 1996 damage
summaries addressing alleged releases from the Cyprus Sierrita Mine and Mill.  Again, all of the issues
identified at Sierrita are water-related and have been addressed under the Clean Water Act or Arizona's
APP program. As with Cyprus Miami, Cyprus Sierrita has made substantial investments in new process
facilities to prevent the types of problems identified in EPA background report.  However, the issues
identified at Sierrita have no relationship to the "mineral processing" activities that the proposed
Supplemental Phase IV LDR rule would regulate."

       Response: While EPA appreciates the additional information, this report includes no damage
       summary for this facility (the specific comment refers to an attachment in which several
       wastestreams were listed); as no inaccuracies addressing the case summary were reported by
       the commenter, no changes were made to the damage summary.
Comments by Cyprus Amax (COMM46) regarding the Copperstone facility in Arizona:

-------
                                                                           ApppnriJY A
The commenter took exception to information reported one of the Attachments to the 1996 damage
summaries addressing alleged releases from the Copperstone facility. The commenter reported the
following: "The facility has been closed since 1992 and is in the final stages of reclamation. None of the
incidents cited are related to the proposed LDR rule. They are spills of in-process solutions, tailings, and
other accidental releases which have nothing to do with secondary materials from mineral processing
operations."

       Response: This specific comment addresses a policy  interpretation. Furthermore, this report
       includes no damage summary for this facility (the specific comment refers to an attachment in
       which several wastestreams were listed); as no inaccuracies addressing the case summary
       were reported by the commenter, no changes were made to the damage summary.
Comments by Cyprus Amax (COMM46) regarding the Sleeper Mine in Humboldt, Nevada:

The commenter took exception to information reported one of the Attachments to the 1996 damage
summaries addressing alleged releases from the Sleeper Mine. The commenter reported the following:
"None of the incidents cited are related to the proposed Supplemental Phase IV LDR rule. They were
spills of in-process solutions, tailings, and other accidental releases which have nothing to do with
secondary materials from mineral processing operations."

       Response: This specific comment addresses a policy interpretation. Furthermore, this report
       includes no damage summary for this facility (the specific comment refers to an attachment in
       which several wastestreams were listed); as no inaccuracies addressing the case summary
       were reported by the commenter, no changes were made to the damage summary.
Comments by Cyprus Amax (COMM46) regarding the Wind Mountain facility in Humboldt,
Nevada:

The commenter took exception to information reported one of the Attachments to the 1996 damage
summaries addressing alleged releases from the Wind Mountain facility.  The commenter reported the
following: "None of the incidents sited are related to the proposed Supplemental Phase IV LDR rule.
They were spills of in-process solutions, tailings, and other accidental releases which have nothing to do
with secondary materials from mineral processing operations."

       Response: This specific comment addresses a policy interpretation.  Furthermore, this report
       includes no damage summary for this facility (the specific comment refers to an attachment in
       which several wastestreams were listed); as no inaccuracies addressing the case summary
       were reported by the commenter, no changes were made to the damage summary.
                                           Page 167

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 Appendix A
 Comments by Cyprus Amax (COMM46) regarding the Nevada Moly Project

 The commenters noted that EPA is the first to describe the Nevada Moly Project as a copper mine.
 While the molybdenum concentrate produced at the mine may have contained co-product copper, it was
 never considered a copper mine.

       Response: The Damage Summary has been changed to reflect that this project was a
       molybdenum mine with copper as a co-product.

 The commenter further noted that the two accidental spills discussed had nothing to do with mineral
 processing, and would  not have been prevented by any aspect of the proposed Supplemental Phase IV
 LDR rule.

       Response: This specific comment addresses a policy interpretation. As no inaccuracies
       addressing the case summary were reported by the commenter, no changes were made to the
       damage summary.
Comments by Kennecott (COMM40)  regarding the Kennecott North and Kennecott South
facilities in Utah:

Kennecott commented that EPA has erroneously stated that "Kennecott North" and "Kennecott South"
zones of KUCC's operations in Utah were added to the NPL in 1994. In addition, the site descriptions
contain factual misstatements. The commenter requested that both references be stricken from the record
and removed from the docket. Contrary to the OSW representations and statements, the Kennecott North
Zone and the Kennecott South Zone sites were only proposed for listing on the NPL(see notice of
proposed rulemaking, January 18, 1994, 59 Fed. Reg. 2568), but that listing was never finalized.  The
commenter noted that OSW should be aware of the fact, particularly as a result of the understanding
reached by Kennecott with EPA in the fall of 1995. On September 26, 1995, Elliott P. Laws, Assistant
Administrator of the Office of Solid Waste and Emergency Response for the U.S. Environmental
Protection Agency, executed a Memorandum of Understanding (MOU) with Kennecott and the State of
Utah, which provides in part that EPA would take no further action relating to the final listing of the
Kennecott North Zone and the Kennecott South Zone on the NPL unless KUCC fails to perform the
activities as described above, "and that EPA would proceed to withdraw the sites from proposal for
inclusion on the  NPL after construction of all cleanup projects is completed." Kennecott is continuing to
perform the activities described in the MOU and believes there is no reason why EPA would take further
action to finalize the proposed listing given the status of the MOU.

       Response: The Damage Summaries were revised to show that neither the Kennecott North nor
       Kennecott South facilities were placed on the NPL; rather, the summaries show that both sites
       were proposed to be added to the NPL. It should be noted that the MOU clearly states that a
       wide range of contamination has occurred at this site and that the company agrees to take a
       range of actions to remediate the site.  The fact that the site was not listed on the NPL should
       not be construed that contamination at the site is not significant.
                                          Paee 168

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                                                                                       jy A
The commenter, in comments submitted in 1997, also noted that many of the practices or incidents cited
at KUCC facilities were historic in nature and occurred prior to 1990. Because the methodology for the
Damage Cases background document was to include only those processes occurring since 1990. many of
the KUCC cases should be excluded in the document. The commenter cited two examples of such
historic practices:

       1)     KUCC terminated the practice of long-term land storage of flue dust prior to September
              1991 when this flue dust became regulated as a newly identified mineral processing
              waste.

       2)     The use of the  refinery electrolyte purification (EP) pond was also ceased in 1974. The
              sludges from the pond were removed in 1972 and 1982. Modern day operations recycle
              the electrolyte  bleed solution. The KUCC facility continues to cooperate with the Utah
              Department of Environmental Quality's permitting requirements.

       Response: This specific comment addresses a policy interpretation. As no inaccuracies
       addressing the case summary were reported by the commenter, no changes were made to the
       damage summary.
Comments by Phelps Dodge (COMM38) regarding the Chino Mine facilities in NM:

The commenter reported the following issues:

•      "The documents also provide false or misleading information on the Chino Mines facility.  For
       example, the 1994 Mining Release document states that the segment of Whitewater Creek in the
       vicinity of the Chino Mine and smelter "was considered for listing on the NPL." This is
       inaccurate.  Although the New Mexico Environmental Department ("NMED"), on behalf of
       EPA, conducted various studies of several sites at and in the vicinity of the Chino Mine, there
       has been no action to list the Chino Mine on the national Priorities List ("NPL").

       Response: This comment addresses possible inaccuracies in the 1994 Mining Waste Releases
       and Environmental Effects Summary for the State of Arizona; the comment does not address
       any inaccuracy in the data summarized in this report. As no inaccuracies addressing the case
       summary were reported by the commenter, no changes were made to the damage summary.

•      NMED and Phelps Dodge have entered into a comprehensive Administrative Order on Consent
       that covers the entire mining operation, including impacts from historical mining activities
       conducted prior to Phelps Dodge's ownership and unrelated to the past or current operation of
       the Chino Mine."

       Response: The information submitted regarding the Administrative Order on Consent was
       added to the Damage Summary; the Agency, however, has not verified the information
       reported by the company.
                                          Paee 169

-------
Appendix A
       "The 1996 Human Health and Environmental Damages document also erroneously states that
       discharges of acidic water from the Chino Mines copper precipitation plant to Whitewater Creek
       (incorrectly referred to as "Whitewood Creek") are a source of contamination at the site.
       However, the document fails to acknowledge that: 1) these charges occurred at permitted outfalls
       under an existing NPDES permit; and (2) the May 1986 discharge referred to in the document
       was permitted under the "upset" provision of the facility's NPDES permit. Because these
       discharges to Whitewater Creek were adequately addressed by EPA Region VI and Phelps
       Dodge pursuant to the federal Clean Water Act, the commenter did not understand why that the
       Mineral Release Document states that no information was available on the specific source,  cause.
       or quantity of the surface water discharges from the Chino Mine or on the corrective measures or
       regulatory actions taken in response to the discharges. The commenter asserted that this
       statement suggests that a complete review of the Chino Mine site was not conducted, and raises
       questions regarding EPA's use of these two documents to support any type of increased
       environmental regulation, particularly the imposition of additional hazardous waste regulatory
       requirements on mineral processing wastes managed in land-based units."

       Response: The Damage Summary incorrectly reported the name of "White-wood Creek;" the
       Summary was revised to show the correct name of "Whitewater Creek." The Summary was
       also amended to include the information provided by Phelps Dodge regarding the facility's
       NPDES permit.

       The May 1986 discharge referred to in the 1996 Human Health and Environmental Damages
       document was permitted under the "upset" provision of the facility's NPDES permit.

       Response: The Damage Summary was revised to incorporate this information;

       The 1994 Mining Release Document also mistakenly lists several alleged sources of surface
       water contamination that no longer discharge to surface waters. Neither runoff from the Chino
       tailings pond, or discharges from the copper leach circuit go to surface waters. Moreover, Phelps
       Dodge has constructed an extensive stormwater and process wastewater system, including
       additional holding reservoirs and an automated sampling system, and has created sophisticated
       water management contingency plans which are part of the State approved discharge plans.

       Response: The Damage Summary was revised to show the existence of a newly constructed
       stormwater and process wastewater system,  as reported by Phelps Dodge. The Summary  was
       further revised to include the information submitted regarding the lack of discharge to surface
       water;
Comments by Phelps Dodge (COMM38) regarding the Tyrone Mine facilities in NM:

The commenter noted that the draft 1994 EPA Mining Release Document and the 1996 Human Health
and Environmental Damages document stated that the Tyrone Mine is a potential source of elevated total
dissolved solids ("TDS") and sulfate in ground water due to "current mineral processing operations."
However, no mineral processing operations ever have been conducted at the Tyrone Mine.

-------
	Appendix A

       Response: The Damage Summary was revised to acknowledge Phelps Dodge's comment that
       no mineral processing occurred at the Tyrone Mine facility;

The commenter further notes that while "tailings" may be the source of the IDS and sulfates. tailings are
beneficiation wastes exempt from RCRA under the Bevill Amendment. In either case, the Tyrone Mine
site does not support EPA's attempt to impose additional hazardous waste regulatory requirements on the
"secondary materials" addressed in the Proposed Rule.

       Response: If the material in question si actually tailings generated from beneficiation, that
       wastes would not be affected by todays rule.
Comments by Phelps Dodge (COMM38) for CoZinCo regarding the Smeltertown site in Colorado:

The commenter noted that the environmental damages cited for the Smeltertown facility involved wood-
treating operations and smelter air emissions, and neither activity is applicable to the proposed rule.

       Response: The Agency disagrees, both wood preserving and mineral processing wastes have
       caused contamination at the site.
Comments by Phelps Dodge (Comm38) regarding the Torch Lake facility in Michigan:

The commenter noted that operations at that site ceased in 1968, and the main concern at the site was the
tailing placed in the lake. Not only do operations at the site long predate RCRA, and involve Bevill-
exempt wastes, but an investigation by the United States Bureau of Mines found that the tailing actually
release very little metal to the lake.

       Response: The substantive information in this comment is already reflected in the damage
       summary. The argument that the material is Bevill-exempt and also a result of historical
       practices reflects a policy interpretation. As no inaccuracies addressing the case summary
       were reported by the commenter, no changes were made to the damage summary.
Comments by Sonora Mining Company (COMM29) regarding the Jamestown Mine:

The commenter presented line-item changes (i.e. page, paragraph, and line) addressing the 1994 Mining
Waste Release and Environmental Effects Summary for the State of Nevada document:

•      In reference to the use of cyanide and mercury for the extraction of gold from the tailings, the
       commenter stated that only cyanide was used in the leaching process.

       Response: The Damage Summary was revised to incorporate the information submitted;
                                          Page 171

-------
ApppnHi*  A
•      The state summary reported that leaching and flotation tailings were disposed of in the tailings
       management facility. The commenter reports that no leaching was done on site.

       Response: The Damage Summary was revised to incorporate the information submitted;

•      In reference to the January 2,  1987 spill, the commenter states that no release to the App pond
       occurred.

       Response: The Damage Summary was revised to incorporate the information submitted;

Comments by U.S. Borax (COMM20) regarding the U.S. Borax Mine in California:

The commenter submitted the following remarks:  Regarding the information on ground water
contamination due to the lack of liners on Impoundments 1, 2, and 3, the information in the damage case
summary is incomplete and thus somewhat misleading because it does not explain the remedial actions
that U.S. Borax has taken since 1990.  Since  1990, U.S. Borax has made an  extensive effort to remediate
this contamination. The boundaries of the contamination have been identified through detailed analysis
of our ground water monitoring well system and other means of ground water monitoring, and
monitoring wells have been added as needed. Based on this analysis, a series of ground water extraction
wells have been installed to contain the contamination within its current boundaries and begin to reduce
the contamination level.

       Response: The Damage Summary was revised to include the information presented discussing
       the remediation efforts taken.
Comments by US Tungsten (COMM 13) regarding Pine Creek Operation in California:

In reference to the release to the Pine Creek Drainage reported March 6, 1990 to the California Regional
Water Quality Control Board, the commenter made the following remarks:

•      The release was in process materials and not mining wastes; there was no long term
       environmental impact associated with the discharge. The elevated TDS levels were still below
       California drinking water standards and returned to below our discharge requirements shortly
       after the discharge was controlled; and there  was no regulatory  response to the event and no
       remedial action was needed;

       Response: The Damage Summary was revised to show that the TDS levels returned to meeting
       limits in the basin plan.

•      The commenter did not feel that a release of in-process materials is an appropriate basis for
       basing rules on mineral processing wastes.

       Response: This specific comment addresses a policy interpretation. As no inaccuracies
       addressing the case summary were reported by the commenter, no changes were made to the
       damage summary.

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Attachment: Mining Waste Releases and Contaminants for Selected Facilities
                               COPPER
SITE
Cyprus Miami Mine.
Claypool, AZ
Magma Copper, Miami
Tailings Reprocessing Pit
and Copper Cities Pit,
Miami, AZ
Oracle Ridge Mine.
Pima County, AZ
ASARCO, Ray Mines,
Gila County, AZ
WASTE RELEASED
copper leachate
waste water
non-potable water
pregnant leachate
recycle
slurry
effluent
copper concentrate
tailings
process water
acidic water
cooling tower
blowdown
sulfur dioxide
gasoline
sulfuric acid
PCB dielectric fluid
diesel fuel
AMOUNT
amount unknown
amount unknown
37,000 gal
min 185,000 gal
5,000-10,000 gal
1,320 gal
15,600 gal
35,000 gal
1.000-2,000 gal
216,600 gal
amount unknown
100 Ibs
1 ton
5,000 gal
amount, unknown
4,340 m3 day
amount unknown
amount unknown
20 tons
10 gal
amount unknown
YEAR
1990
1980
1985
1986
1990
1989
1984
1989
1989
. 1989
1991
1991
1991
1991
1991
1991
1985
1985
1988
1989
1989
1989
1989
                                 A-l

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Attachment:  Mining Waste Releases and Contaminants
          for Selected Facilities (continued)
SITE
Siernta Mine and Mill.
Cyprus Minerals Corp.,
Pima County. AZ
Chino Mines, NM
Tyrone Mine, NM
Montana Resources, Inc.
Butte, MT
Bully Hill Mine,
Redding, CA
Penn Mine, New Penn
Mines, Inc. Campo Seco,
CA
Walker Mine,
Calicopia Corp.,
Plumas County, CA
Mammoth, Keystone &
Stowell Mines,
Shasta County, CA
Red Ledge Mine, NV
WASTE RELEASED
tailings
process water
pregnant leachate
heavy metals &
sulfuric acid
acidic water
TDS & sulfuric acid
from tailings
leach
tailings
acid mine drainage
acid mine drainage
leaching of heavy
metals
heavy metals
acid mine drainage
acid mine drainage
see "Gold and Silver"
AMOUNT
10,469 acre feet
5,085 acre feet
1 gal/min
amount unknown
amount unknown
16,200 gal
min 2 million gal
4,270 acre feet/year
amount unknown
83 million tons
30 gal/min
amount unknown
flow ratftrunknown
amount unknown
amount unknown
100-275 gal/min

YEAR
1981
1987
1987
extended
extended
1986
1988
1978-79
1986
1986
since 1921
since 1955
unknown
unknown
since 1941
extended

                        A-2

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Attachment: Mining Waste Releases and Contaminants
          for Selected Facilities (continued)
SITE
Arimetco Facility.
Arimetco Inc.;
Copper Tek Corp..
Lvon County, NV
Nevada Moiy Project,
Cyprus Tonopah Mining,
Tonopah, NV
Rio Tinto Mine.
U.S. Forest Service,
Elko County, NV
WASTE RELEASED
acid leach
pregnant soln.
process solution
mercury
acid
tailings
AMOUNT
amount unknown
amount unknown
amount unknown
5.783 kg
amount unknown
amount unknown
(11 spills)
YEAR
1989-91
1989
1989-
1990
extended
1958-81
                   MOLYBDENUM
SITE
Montana Resources Climax
Mine,
AMAX Mineral Resources
Corp.,
Lake, Eagle, Summit &
Park Counties, CO
Urad Mine & Mill,
Climax Molybdenum Co.,
Climax. CO
Nevada Moly Project
WASTE RELEASED
see "Copper"
windblown tailings
tailings
see "Copper"
AMOUNT

large though
unknown amount
6.3-47.4 cfs

YEAR

1986
1987
extended

                       A-3

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Attachment:  Mining Waste Releases and Contaminants
         for Selected Facilities (continued)

                    ANTIMONY
SITE
U.S. Antimonv Corp., MT
WASTE RELEASED
tailings
QUANTITY
amount unknown
YEAR
extended
                   LANTHANIDE
SITE
Mountain Pass Mill &
Mine, Moly Corp.,
San Bernadino, CA
WASTE RELEASED
waste water
QUANTITY
3,375 gal
44,625 gal
YEAR
1989
1990
                    MERCURY
SITE
Mount Diablo Mine,
Contra Costa County, CA
Central Valley of CA
WASTE RELEASED
tailings, waste rock,
overburden
see "Gold and Silver"
QUANTITY
amount unknown

YEAR
1978-
p resent

                   TUNGSTEN
SITE
U.S. Tungsten Corp.,
Pine Creek Operations,
Inyo County, CA
WASTE RELEASED
TDS from ammonium
paratungstate plant
fluoride
QUANTITY
2,419 gal/day
amount unknown
YEAR
1990
extended
                      A-4

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Attachment: Mining Waste Releases and Contaminants
         for Selected Facilities (continued)

                      BORAX
SITE
U.S. Borax Mine.
Kern County. CA
WASTE RELEASED
waste water
QUANTITY
300 gal/min
YEAR
1990
                     SULFIDES
SITE
Golinsky Mine.
Shasta Lake, CA
WASTE RELEASED
acid mine drainage
QUANTITY
20 gal/min
YEAR
since
1937
            TRONA, BORAX, BRINE SALTS
SITE
Trono, Argus, Westend
Facilities,
North American Chemical
Co.,
Trono, CA
WASTE RELEASED
brine liquor



sulfuric acid
mercury
unknown vapor
monoethanolamine
hydrocarbons
QUANTITY
3,000-5,000 gal



20 gal
40 Ibs
unknown
1,000 gal
1,000 gal
YEAR
1989



1989
1989
1989
1990
1990
                       A-5

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Attachment: Mining Waste Releases and Contaminants
          for Selected Facilities (continued)
                  LEAD AND ZINC
SITE
Black Cloud Mine,
Res-ASARCO Joint
Venture,
Lake County. CO
Taylor/Ward Project,
Alta Gold Co-
White Pine County, NV
Central Valley of CA
Red Ledge Mine, ID
Montana Tunnels Mine.
MT
Lucky Friday Mine,
Mullan, ID
WASTE RELEASED
copper sulfate
water and sediments
acid leak
lead only,
see "Gold and Silver"
zinc only
see "Gold and Silver"
zinc only
see "Gold and Silver"
see "Gold and Silver"
see "Gold and Silver"
QUANTITY
2 gal
id" gal
50 gal
unknown amount
amount unknown
amount unknown





YEAR
1987
1987
1987
1987
1983
unknown





                        A-6

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Attachment: Mining Waste Releases and Contaminants
         for Selected  Facilities (continued)
                 GOLD AND SILVER
SITE
American Girl Mine.
American Girl Mining Co-
Imperial County, CA
Carson Hill Gold Mine,
Western Mining Co.,
Calavaras County, CA
Goldfields Operating Co.,
Mesquite, CA
Goldstripe Project,
Plumas County, CA
Gray Eagle Mine,
Noranda. Siskivou County,
CA
Jamestown Mine,
Sonora Mining Corp.,
Tuolumne County, CA
WASTE RELEASED
pregnant solution
process solution
barren solution
pregnant leach solution
leaching solution
leaching solution
residue solution
tailings
untreated water
flotation solution
reagents
process water
tailings slurry
soda ash solution
QUANTITY
1,700 gal
4,320-8,640 gal
5,000 gal
91,450 gal
amount unknown
770 gal
50 gal
2,520 gal
33 gal
26 gal
amount unknown
amount unknown
15 & 30 gal/min
1.000-1,500 gal
19, 100 gal
2-3 gal/min for hours
500 gal
2,700 gal
1,000 gal
1,500 gal
1,500-2,000 gal
2.000 gal
3,000 gal
YEAR
1987
1988
1989
1989
1985
1990
1990
1990
1990
1990
1986
1986-87
1983
1983
1986
1989
1987
1987
1989
1990
1990
1990
                       A-7

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Attachment:  Mining Waste Releases and Contaminants
          for Selected Facilities (continued)
SITE
Jamestown Mine,
Sonora Mining Corp..
Tuolumne Countv. CA
(Continued)
Kanaka Creek Joint
Venture,
AJleghany. CA
McLaughlin Mine,
Homestake Mining Co.,
Napa & Yolo Counties, CA
Morning Star Mine,
Vanderbilt Gold Corp..
San Bernandino, CA
Mt. Gines Mine,
Texas Hill Mining Co.,
Mariposa. CA
Central Valley of CA
numerous closed mines
Picacho Mine,
Chemgold Inc..
Imperial County, CA
Snow Caps Mine,
Sunshine Mining Co.,
Independence, CA
Yellow Aster Mine,
Rand Mining Co.,
Randsburg, CA
WASTE RELEASED
supernatant
concentrate
effluent with arsenic
ore slurry
pregnant solution
leaching solution
acid mine drainage:
copper, zinc,
cadmium
iron
cyanide solution
leaching solution
leaching solution
QUANTITY
20 gal/min
amount unknown
10 tons
amount unknown
28 gpm
amount unknown
2.500 gal
308,000 gal
2 tons/year
22 tons/year
min 1.200 gal
6,000 gal
amount unknown
amount unknown
YEAR
1987
1988
1990
1991
1989
1989
1988
1991
extended
since 19S7
1989
1988
1989
                        A-8

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Attachment: Mining Waste Releases and Contaminants
          for Selected Facilities (continued)
SITE
Atlantic and Pacific Mine.
2900 Development Corp..
Madison County. MT
Basin Creek Mine,
Lewis & Clark and
Jefferson Counties, MT
Cable Creek Project,
Deer Lodge County, MT
Gies Mine,
Virginia Gulch Mine,
Heath Mill.
Blue Range Mining Co.,
Fergus County, MT
Golden Sunlight Mine,
Placer Amex, Inc.,
Whitehall. MT
Mineral Hill.
Mine/Jardin Joint Venture,
Jardine. MT
Landusky Mine,
Zortman, MT
Montana Tunnels Mine,
Jefferson County, MT
W/^STE RELEASED
effluent
acid mine drainage
cyanide
effluent from main
sediment pond
tailings
tailings
pregnant solution
acidic water
waste rock
tailings
seepage return solution
cyanide
cyanide
pregnant solution
cyanide
QUANTITY
amount unknown
amount unknown
amount unknown
amount unknown
amount unknown
amount unknown
amount unknown
amount unknown
2,000 gal
amount unknown
amount unknown
small amount
20-50 gal
200 gal
few gal/hour
amount unknown
amount unknown
amount unknown
YEAR
1988
extended
1988
1989
1989
1990
1983
1987
1986
1980
1987
1991
1990
1990
1987
1988
1987
1988
                        A-9

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Attachment: Mining Waste Releases and Contaminants
          for Selected Facilities (continued)
SITE
Pony Custom Gold Mill.
Chicago Mining Corp..
Pony. MT
Radersburg Mill.
Broadwater County, MT
New Butte Mining, Inc.,
Continental and Silver
Bow County, MT
Copperstone Project,
Parker. AZ
Portland Mine.
Bullhead City, AZ
Bullger Basin Mine,
Pennsylvania Mining Inc.,
Park City. CO
Cross Gold Mine,
Hendricks Mining Co.,
Caribou. CO
Jerry Johnson Group
Cyanide Leach.
El Paso County, CO
Rubie Heap Leach,
American Rare Minerals
Inc.,
Teller County, CO
WASTE RELEASED
tailings
tailings
superfund site
leaching solution
tailings
process solution
process water
slurry
heap slide
oil
copper, lead
fresh ore
cyanide
QUANTITY
20 gal/day
max 15 gal/day
amount unknown
amount unknown
large spill

2,000 gal
5 gal
5,600 gal
7,500 gal
500 gal
500 gal
150-200 gal
500 gal
300-400 gal
200 gal
amount unknown
amount unknown
amount unknown
amount unknown
amount unknown
YEAR
1990
1990
1990
1986
1985

1987
1988
1987
1988
1989
1989
1990
1988
1990
1992
1986
1986
1990
1986
1985-1992
j
                       A-10

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Attachment:  Mining Waste Releases and Contaminants
          for Selected Facilities (continued)
SITE
Gilt Edge Project.
Brohm Mining Co..
Deadwood, SD
Annie Creek Mine,
Wharf Resources,
Lawrence County, SD
Golden Reward Mine,
Lead, SD
WASTE RELEASED
cyanide
process solution
neutralization solution
pregnant solution
leaching solution
process water
leachate
cyanide
pregnant solution
neutralization solution
sedimentation pond
diesel fuel
carbon slimes
diesel free product
barren solution
QUANTITY
amount unknown
amount unknown
300 gal
1,329 gal
47.05 gpd
amount unknown
1 gal/hour
amount unknown
amount unknown
100 gal
10.000 gal
amount unknown
200 gal
50-60 gal
amount unknown
500 gal
1,000 gal
amount unknown
1.288 gpad
1,317 gpad
5 gal
amount unknown
amount unknown
amount unknown
amount unknown
4.000 gal
amount unknown
amount unknown
500 gal
YEAK
1991
1991
1990
1989
1989
1988-W
1986
1989
1987
1988
1990
1984
1984
1984
1985
1988
1990
1990
1991
1991
1984
1989
1990
1989
1990-91
1987
1990
1991
1990
                       A-ll

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Attachment: Mining Waste Releases and Contaminants
          for Selected Facilities (continued)
SITE
Golden Reward Mine.
Lead, SD (Continued)











Homestake Gold Mine,
Lead. SC

Richmond Hill Mine,
Bond Gold Co.,
Lawrence County, SD

Brewer Gold Mine.
Westmont Mining Inc.,
Jefferson, Chesterfield
Counties, SC








WASTE RELEASED
leach heap

surge pond solution
cyanide








hydraulic oil
cyanide

waste bench run-off
cyanide


ore
process water



cyanide


partially leached ore
barren solution



QUANTITY
300 gal/cell

500 gpad
120 gal
125 gal
1,000-2,000 gal
400 gal
50 gal
29 gal
25-50 gal
25-50 gal
200 gal
150 gal
amount unknown

amount unknown
200 gal
1,350 gal
150 gal
40 tons
amount unknown



1,800 gal
1,683
10-12 million gal
500 tons
750 gal
1,000 gal
1,000 gal
150 gal
YEAR
1990

1990
1990
1990
1990
1989
1989
1990
1990
1991
1991
1990
1988

1988
1989
1990
1990
1990
1987



1988
1989
1990
1987
1990
1987
1988
1988
                       A-12

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Attachment: Mining Waste Releases and Contaminants
          for Selected Facilities (continued)
SITE
Brewer Gold Mine,
Westmont Mining Inc..
Jefferson, Chesterfield
Counties, SC (Continued)
Lucky Friday Mine,
Helca Mining Co.,
Mullan, ID
Microgold II Mine,
Powell & Micro Gold II,
Florence. ID
Princess Blue Ribbon
Mine,
Precious Metals
Technology,
Camas County, ID
Red Ledge Mine,
Aha Gold Co.,
Adams County, ID
Stibnite Mine Project,
Valley County, ID
WASTE RELEASED
pregnant solution
emergency pond
solution
ore
rinse solution
spent ore
tailings
copper sulfate
mercury
tailings
tailings
cyanide
sediment
acid mine drainage
diesel oil
cyanide
QUANTITY
500-600 gal
8,741 gal
300-2,250 gal/day for
fourteen days
100 tons
amount unknown
2,250 gal
125 ft3
amount unknown
amount unknown
100 gal
12 Ibs
amount unknown
amount unknown
amount unknown
amount unknown
0.2 cfs
900 gal
amount unknown
YEAR
1988
1990
1989
1989
1990
1989
1989
1988
1988
1988
1983
1984
1990
1988-90
1990
since 1973
1989-90
1989
                       A-13

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Attachment:  Mining Waste Releases and Contaminants
          for Selected Facilities (continued)
SITE
Stibnite Mine Project,
Valley County. ID
(Continued)
Yellow Jacket Mine,
Glen Martin,
Cobalt. ID
ACH-Dayton Project,
American Eagle Resources,
Lyon County, NV
.Alligator Ridge Mine,
USMX Inc.,
Ely, NV
Aurora Gold Project,
Aurora Partnership,
Mineral County. NV
Bald Mountain Mine,
Placer Dome US Inc.,
White Pine County, NV
Big Springs Project,
Independence Mining Co.,
Elko County, NV
Borealis Gold Project,
Tenneco Mining,
Mineral County, NV
Buckhorn Mine.
Cominco American Inc.,
Eureka County, NV
WASTE RELEASED
tailings
cyanide
cyanide
barren pond
cyanide
pregnant solution
process water
pregnant solution
barren solution
tails liquor
cyanide
cyanide
process solution
QUANTITY
amount unknown
unknown
amount unknown
amount unknown
100,000-200,000 gal
32,000-34.000 gal
amount unknown
amount unknown
amount unknown
amount unknown
4,500 gal
9,000 gal
5.000 gal
23.000 gal
amount unknown
2,000 gal
1.000 gal
3,000-5,000 gal
YEAR
since 1980
1986
1986
19K9
198?
1986
1986
. 1985-19X9
1990
1990
1988
1989
1991
1989
1990
1988
1988
1990
                       A-14

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Attachment:  Mining Waste Releases and Contaminants
          for Selected Facilities (continued)
SITE
Buckskin Operation.
Sonora Mining Corp..
Douglas County. NV
Candelaria Mine,
Necro Metals Inc.,
Hawthorne. Esmeralda,
Mineral Counties, NV
Chimney Creek Project,
Gold Fields Mining Corp.,
Humboldt County, NV
Coeur Rochester,
Love Lock, Pershing
County, NV
Cortez Gold Mines,
Cortez Joint Venture,
Cortez. NV
Crofoot & Lewis Projects,
Hycroft Resources &
Development,
Humboldt County, NV
Dee Gold Mine,
Dee Gold Mining Co..
Elko, NV
WASTE RELEASED
tailings
pregnant solution
ammonium nitrate
cyanide
descant solution
diesel fuel
hydraulic oil
barren solution
pregnant solution
tailings
process solution
pregnant solution
tailings reclaimed water
QUANTITY
amount unknown
20,000-25,000 gal
4,940 Ibs
Igal
400 gal
360 gal
SOL
80 gal
10 gal
125 gal
78 gal
90,000-130,000 gal
5,000-10,000 gal
amount unknown
600 gal
5,000 gal
228,000 gal
72,000 gal
17,000 gal
142,968 gal
YEAR
1990-91
1986
1991
1991
1991
1991
1991
1991
1991
1991
1991
1987
1987
since 19S1
1991
1990
1990
1990
1991
1986
                       A-15

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Attachment:  Mining Waste Releases and Contaminants
          for Selected Facilities (continued)
SITE
Dee Gold Mine.
Dee Gold Mining Co.,
Elko. NV (Continued)
Denton-Rawhide Project,
Kennecott Rawhide
Mining Co.,
Mineral County, NV
Easy Junior Mine.
AJta Gold Co.,
White Pine County, NV
Elder Creek Mine,
AJta Gold Co.,
Lander County, NV
Florida Canyon Mine,
Pegasus Gold Corp.,
Pershing County, NV
Flowery Project,
American Eagle Resources,
Virginia City, NV
Gretchell Mine,
First Miss Gold Inc.,
Winnemucca, NV
WASTE RELEASED
tailings
cyanide
safety pond solution
used oil
barren solution
pregnant solution
pregnant solution
leaching solution
barren solution
cyanide
leaching solution
laboratory samples
sulfuric acid
QUANTITY
12,000
10.340 gal
581bs
amount unknown
167 gdp
13 barrels
3,000 gal
4,000 gal
small amount
amount unknown
10,000 gal
30 gal
112 gal
1.200 gal
5,00 gal
amount unknown
160-290 mL/min
amount unknown
8-16gpd
20 gal
YEAR
1989
1989
1990
1991
1990
unknown
1989
1990
1990
1990
1990
1991
1990
1990
1988
1991
1991
1989-1990
1991
                       A-16

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Attachment: Mining Waste Releases and Contaminants
          for Selected Facilities (continued)
SITE
Gold Bar Project.
Atlas Gold Mining Inc..
Eureka County, N'V
Golden Butte Project.
Alta Gold Co..
White Pine County, NV
Gooseberry Tailings Pond,
Asamera Minerals Inc.,
Storey County, NV
Haywood Leach Facility,
Oliver Hills Mining Co.,
Lyon County, NV
Hog Ranch Mine,
Western Mining Co.,
Valmy, NV
Jerritt Canyon Project,
Elko County, NV
Marigold Mine,
Marigold Mining Co.,
Valmy, NV
Mother Lode Project,
US Nevada Gold Search
Joint Venture,
Beatty, NV
WASTE RELEASED
cyanide
process fluid
pregnant solution
cyanide
barren solution
cyanide
cyanide
barren solution
cyanide
tailings
tailings
leaching solution
pregnant solution
cyanide
QUANTITY
amount unknown
amount unknown
2.4 gpm
6,500-17,500 gal
1,000 gal
75 gal
50-55 gal
amount unknown
300 gal
amount unknown
250,000 gal
3,500 gal
20,000 gal
amount unknown
3,000 gal
amount unknown
228 gpd
640 gpd
.4 Ibs
YEAR
1988
1989
1989
1989
1990
1990
1990
1990
1990
1989
1989
1990
1989
1990
1991
1991
1989
199')
1990
                       A-17

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Attachment: Mining Waste Releases and Contaminants
          for Selected Facilities (continued)
SITE
Mill No. 4,
Newmont Gold Co.,
Eureka County, \V
Nevada Mineral Processing
Mill,
Nevada Mineral Processing,
Mineral County, NV
North Area Leach Project,
Newmont Gold Co.,
Eureka County, NV
Northumberland Mine,
Western Minerals Corp.,
Nye County, NV
Paradise Peak Project,
FMC Gold Co..
Nye County, NV
Rain Facility,
Newmont Mining Co.,
Carlin. NV
Santa Fe Project,
Corona Gold Inc.,
Hawthrone, NV
Silver Peak Project,
Homestead Minerals Corp.,
Esmeralda County, NV
WASTE RELEASED
tailings
cyanide
pregnant solution
pregnant solution
leaching solution
cyanide
acid drainage
leaching solution
waste oil
barren solution
cyanide
lead thickener
\£tit^pPt 1 1 1 I
2 gpm
amount unknown
2,500 gal
555,000 gal
400 gal
8-100 gal
275 Ibs
481bs
3 gpm
5 gpm
amount unknown
amount unknown
20-25 gal
8,000-10,000 gal
15 gal
750 gal
YEAR
1990
1991
198X
1983
1985
1989
1989
1991
1990
1989
1989
1990
198S
1986
1991
1991
                       A-18

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Attachment:  Mining Waste Releases and Contaminants
          for Selected Facilities (continued)
SITE
6-Mile Canyon Project,
Gold Canyon Placer Inc.,
Dayton. NV
Sleeper Mine.
Amax Gold Inc.,
South Leach Project,
Newmont Gold Inc.,
Eureka County, NV
Tonkin Springs Gold
Mining Co.,
Eureka County, NV
WASTE RELEASED
cyanide
tailings
reclaimed seepage
pond solution
barren solution
cyanide
pregnant solution
process solution
ore processing
evaporation pond
mill make-up water
pregnant solution
pregnant solution
leach seepage solution
QUANTITY
amount unknown
10 tons
1,000 gal
19.320 gal
610 gal
3,000 gal
2,000 gal
300 gal
2,000 gal
4,000 gal
149 Ibs
7.66 Ibs
265 Ibs
amount unknown
4, 100 gal
6,240 gal
45,000 gal
1 gpm
3,000
amount unknown
amount unknown
500,000 gal
amount unknown
amount unknown
YEAK
1986
1990
1988
1989
1989
1989
1989
1989
1989
1990
1989
1990
1990
1990
1991
1991
1990
1990
1990
1991
1991
1988
1988
1990
                       A-19

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Attachment: Mining Waste Releases and Contaminants
          for Selected Facilities (continued)
SITE
USX Project.
Ivanhoe Gold Co.,
Elko County. NV
Willard Project,
Western States Mineral
Corp.,
Pershing County, NV
Wind Mountain Project,
Washoe. NV

Taylor/Ward Project,
Alta Gold Co.,
White Pine County, NV
WASTE RELEASED
leaching solution

pregnant solution

barren solution
strip solution
cyanide

tailings, silver only

QUANTITY
150 gdp
amount unknown

450 gal

100 gal
600 gal
450 gal
6,000 gal
385,000 gal
1.7 Ibs
300 gal
30 gal
30,000 gal

YEAR
1990
1991

1989

1989
1990
1989
1990
1989
1990
1991
1991
1990

                       A-20

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_?T3, 02 ' 93 !MON)_ := • 3C
                                               !3 903 '.372
                                         •T.t*.iti4 HIM
                            Department of

                  Environmental  Protection
   Uwen CMfe*
                              1104 C««nwt him Dnve
                                                                 fi
-------
grg M3T TPMPP SUDIST
                         P';   ii
                         ISlil Ii rill I

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   703 903 1 372

        " •
                                       PAGE. 3/5

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Supplemental Attachment  to  the Technical  Background Document  on
Human  Health  and Environmental Damages  from Mining and Mineral
Processing Wastes

MEMORANDUM
                               December 11, 1995'
                             e. i. •
From:      Van E.  Housman, Industrial and Extractive  Wastes  Branch

To:        RCRA Docket F-95-PH4A-FFFFF

Subject:   Natural Resource Damages from Mining Operations


     There are over  60  mining sites1- on  the  National Priorities
List  (NPL) .   Many  of  thesa  sites  are  a reault  of  acid mine
drainage.2   Cost  estimates for  hardrock mining cleanup may  exceed
several billion dollars.3  About half of the current NPL mine sites
owe  a  significant  part  of  their  environmental  problems  to  the
gradual release of lead,  arsenic,  chrome'/  and other contaminants
from acid  rock  drainage.4  Depending  on  location,  geology,  and
climate,   acid  rock  drainage  problems  can   be   ao  severe that
perpetual  treatment may be required.5 The natural resource damages
resulting  from these  and other  mine sites can be severe.

     Federal .and ,state  authorities  have  the ability  to collecc
natural  resource damages from  mining companies.'   For  example,
CERCLA  allows a  federal  or state  authority  to be a trustee  for
     1 OFFICE OF  SOLID WASTE, U.S. EPA, MINING WASTE SITES ON THE NATIONAL
PRIORITIES  LIST (1995).     -  .

     3  The  National-  Priories  List   (NPL)  identifies  the  mosc
significant  hazardous  waste  sites  that are targeted for long term
cleanup under Superfund.   See  40 C.F.R.  §  35.6015(a) (27) (1994) .

     3   The  Mineral  Policy  Center,  Washington D.C.  estimates
557,650 abandoned hardrock mines in the U.S. would require between
$32.7 billion  to $71.5 billion  for cleanup.   BURDEN OF GILT  (June
1993}.        ,           .

     * Hardrock mining  operations reduce boulder sized rock to fine
grained sand.  This process exposes sulfide minerals in the rock co
water and oxygen,   forming  sulfuric acid.   This acid, generation
dissolves  part  of  the  host  rock,  which  in turn  exposes  more
sulfides.   The  sulfuric  acid  in turn dissolves  metals  and  other
contaminants such  as arsenic  from  the host rock.  Once  started,
this cycle  may  last for  decades or uncil  chese  is no  longer  any
rock to supply  a source of acid.
     *  OFPICS OF SOLID WASTE, U.S. EPA, TSCHN-.CAL ANALYSIS AND EVALUATION ..-
MINING WASTE;  TASK 6: COSTS OF REMEDIATION AT  MINE SITES  (July 1995) .

-------
 natural  resources6,  which  are  defined  as  land,  fish,  wildlife,
 groundwater,  and  other resources  belonging to,  managed by,  or
 otherwise  controlled  by federal  or  ocher  government  enticies.
 CERCLA authorizes the  trustee  to  act  on behalf of  the  public  co
 seek monetary compensation  from the responsible parties to restore
 the natural  resources  that  have been  injured by their actions.

     As  of  April 1995,  98 .natural  resource  damage cases  were
 settled  under CERCLA  for  about  $106  million.7  Hardrock mining
 accounts  for six of  these sites and  a disproportionately  high
 percentage cost  of $35 million.8  Another way to view this is  that
 over 33% of  the  cost of the largest natural  resources damages are
 a  result  of  hardrock  mining.   (This  figure  does'not  include the
 $15.1  million natural'  resource  damages  award by the  court against
 Summitville  Consolidated  Mining  Co.   because  the  company   wenc
 bankrupt.)

     The mining  that haa occurred  for  over 100  years at  the Coeur
 d'Alene  River  basin is but one  example of  long-term cumulative
 effects of pollution.  According to the'Department  of Justice, che
 Coeur  d'Alene River  basin,  which includes over 100  mines  and the
 Bunker Hill Superfund  site,  may require between'$600  million to  $1
 billion to  restore damage  done  to  the natural resource.  Mining
 activities at Coeur, d'Alene have caused wide-spread lead  and other
 heavy metal  contamination of'the area's soil, water,  and air.

     But some State laws are changing to address these large scale
 damages.  For example,  che upper Clark Fork River basin in Montana
 encompasses  nearly 127  miles  of river  contaminated by  over  103
years  of  mining  and  mineral  processing (smelting)  operations.'
     6 CERCLA 42 U.3.C.  §  9607 (f) (1) (1988} .   The Clean Water Act
also allows .the trustee to assess  natural  resource  damages.   33
U.'S.C.  §  1321 (f) (4) - (5) (1988) .    Damages  from  the  hazardous
substances are measured and recoverable in three broad categories:
(1). the cost of  restoration, rehabilitation,  and acquisition of che
equivalent of the  injured natural resources and the services that
those resources provide; (2}  the compensable value of the services
lost to the public from  the time of release until the restorative
measure selected  returns the  resources and  services to baseline;
and  (3) the reasonable cost of assessing the injury.

     7  Testimony   of  Peter  F.   Guerro,  Director,  Environmental
Protection Issues,  Government Accounting Office for Subcommittee on
Wacer Resources and Environment,  House  Committee on Transportation
.and infrastructure Hearing (July 11, 1935) .

     8  id.

     9   Testimony   of  Peter  F.   Guerro,  Director,  Environment-..}1..
Protection Issues,  Government Accounting Office for Subcommittee cr.
Water Resources and Environment,  House  Committee on Transportation
and Infrastructure Hearing, July 11, 1995.

-------
2  '93 ;MO.\;
 Hazardous .substances are still being released from these operations
 and  causing damages.  The  State  of Montana is  seeking  over 560C
 million  in natural resources damages.13  The federal government: has
 not  filed a  damage  claim,  but  could conceivably seek damages that
 rival  the Coeur d'Alene  River  Basin.

 Attachment                          •    '      .
      10   Id.   Montana  Comprehensive  Environmental  Cleanup
 Reaponaibilicy  Act.   Mont.  Code  Ann.  S§  75-10-701  to 75-1
 (1993) .

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Supplemental Attachment to the Technical Background Document on
Human Health and Environmental Damages from Mining and Mineral
Processing.

     Documentation regarding releases from mineral processing
phosphogypsum storage.

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                     United States General Accounting Office
frAO             Testimony
                     Before the Subcommittee on Water Resources and
                     Environment, Committee on Transportation and Infrastructure,
                     House of Representatives
                     SUPERFUND
My 11,1995
Statement Submitted
My 11,1995
                     Number and Value of Natural
                     Resource
                     Damage Claims
                     Statement for the record by
                     Peter F. Guerrero,
                     Director, Environmental Protection Issues,
                     Resources, Community, and Economic Development Division

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Mr. Chairman.and Members of  the  Subcommittee:

     As  the  Subcommittee considers  reauthorizing  the  Superfund
program, we  are pleased to provide  this  statement on  settlements
for damages  to natural resources under the  Comprehensive
Environmental Response, Compensation, and Liability Act  (CERCLA)
Known generally as the Superfund statute, CERCLA  authorizes  the
Environmental Protection Agency  (EPA) to clean up hazardous  waste
sites and to compel responsible parties  to  perform or pay  for  the
cleanups.  CERCLA also authorizes certain federal, state,  and
tribal- authorities to seek monetary damages for injuries to
natural resources (such as wetlands, fish,  and wildlife habitat)
resulting from releases of hazardous substances.   Concerns have
arisen that  such damages could add  billions of dollars to  the
costs of Superfund cleanups and impose heavy burdens  on industry
and the federal budget.

     Our statement presents information on  the number and  value
of claims for natural resource damages and  is based on recently
completed work.  -In particular, we  will  focus on  claims filed  and
settled.  We also present the views of officials  from the
Departments of Justice, Commerce, and the Interior on the  likely
extent of future damage claims, including those faced by federal
agencies, such as the Departments of Defense and  Energy.

     In summary,  relatively few natural resource  damage
settlements have been reached, and  their value is  small compared
to that of Superfund cleanup agreements.  However, some cases  now
outstanding may involve substantial sums—up to hundreds of
millions of dollars.  Moreover, an uncertain number of the
government's facilities may be subject to large damage claims,
which could have potentially significant implications for  the
federal budget.

     As of April 1995, federal agencies had settled -98 natural
resource damage cases1 for  an estimated  total of  $106  million:2

          48 were settled with no payments,

          36 were settled for less  than $500,000  each,

          9 were settled for between $0.5 million  and $5 million
:This  number is based on the Department of Justice's.
classification, which sometimes groups more than one settlement
in a "case."

2We are reporting actual dollar amounts that have not been
adjusted for inflation.  These dollar amounts reflect either cash
settlements or the estimated value of damage assessments or
restoration work that responsible parties have agreed to perform.

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           each,  and

           5 were settled for $12 million or more each.   (See app.


 These five largest settlements accounted for $84.4 million,  or 80
 percent,  of the  $106 million recovered.  In comparison,  through
 fiscal year 1994,  responsible parties had settled Superfund
 cleanup agreements valued at an estimated $10.2 billion—nearly
 100  times the total value of the natural resource damage claims.

      To learn about damage claims that states may have  filed on
 their own,  we contacted nine states.   These nine states  were
 chosen in part because they were known to have pending  or future
 claims that involved large natural resource damages.3  Five
 states had not yet settled any claims without federal  trustees.
 But  four had settled 17 other claims  on their own for a  total of
 approximately $23.4 million—bringing the total value of claims
 identified in our  review to about $129.4 million.

      Federal and state officials could not predict the  number and
 value of  future  natural resource damage settlements.  However,  we
 asked them if they could identify any geographic areas where
 pending or future  damage claims could exceed $50 million.   This
 amount is what some are suggesting should be the statutory limit
 for  such claims.   Because such pending or future cases can be
 sensitive,  these officials were generally reluctant to  identify
 such areas.v However,  they did identify three different  instances
 where the extent and nature of damages have been publicly
 discussed and where pending or future claims are or may  be valued
 at about  $500 million or more.

      Although private parties have been involved in most of  the
 natural resource damage settlements to date,  the federal
 government could become liable for such damages at hazardous
 waste sites on its facilities.  These damages could add
 significantly to the government's cleanup costs,  which,  for  one
 agency alone, the  Department of Energy, are expected to  be about
 $300 billion.

 NATURAL RESOURCE DAMAGES

      With, the passage of CERCLA in 1980,  the Congress authorized
 EPA  to remedy contamination resulting from the release_of
 hazardous substances and to compel the parties responsible for
.generating or disposing of the hazardous waste to help conduct  or
 3The nine states are California, Colorado, Idaho, Minnesota,
 Montana,  New Jersey, New York,  Utah,  and Wyoming.

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pay  for  its cleanup.4  CERCLA also established a trust fund  (the
Superfund), whose  authorization now  totals  $15.2 billion and
which is  financed  primarily by taxes on  corporate  income,  crude
oil, and  certain chemicals.  EPA uses  the trust  fund  to  implement
the  cleanup program and  to pay for cleanup  activities.

     In addition,  CERCLA provides for  designating  federal  and
state authorities  as trustees for natural resources.  These
resources are defined under the law  to include land,  fish,
wildlife, groundwater, and other resources  belonging  to, managed
by,  or otherwise controlled by, federal  or  other governmental
entities.  CERCLA  authorizes the trustees,  acting  on  behalf  of
the  public, to recover monetary compensation  (damages) from
responsible parties to restore natural resources that have been
injured'by the release of hazardous  substances.  The  trustees may
also recover reasonable  costs for assessing any damage to natural
resources.  The trust fund may not be  used  to pay  for- restoring
the  natural resources; therefore, the  trustees must rely on
recoveries from responsible parties  to pay  for this work.  Under
CERCLA,  the recovered damages may be used only to  restore or
replace damaged resources or. to acquire  equivalent resources.
Damages may be recovered for injuries  to resources-in an area
that surrounds or  adjoins a Superfund  site  itself  and for
injuries to areas  where  no Superfund site has been designated.

   •  At some sites, responsible parties  could incur liability for
both cleanups and  damages to natural resources.  Hence,  for  these
sites,  including those on land owned by  federal agencies, the
trustees will generally  seelc recoveries  only for residual
resource damage, or damage that remains  after a cleanup  has been
completed, accordfngLto  Department of  Justice officials.  This
damage may occur when (1) a cleanup leaves  significant^
contamination in the environment or  (2)  animal pbpna-faftfbns have
been reduced or wildlife habitat has been destroyed and  cannot
recover quickly'without  human intervention.

     At the federal level,  the Department of Commerce's  National
Oceanic and Atmospheric Administration (NOAA) and  the Department
of the Interior have broad responsibilities as trustees  for
natural resources.  NOAA is the trustee  for the nation's coastal
and marine environment,   including commercial and recreational
fisheries, anadromous fish,5 and.marine mammals.   Interior is the
trustee for resources•such as migratory  birds and  waterfowl,
Responsible parties may include waste generators,  waste haulers,
and site owners and operators.

5Anadromous species are fish,  like salmon,  that spawn in
freshwater and then migrate to the sea.

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endangered species, and anadromous  fish.6  Federal agencies--such
as the Departments of Agriculture,  Defense,  Energy,  and  the
Interior—are also the trustees  for natural  resources  on the
lands they manage.

     States also have trustee responsibilities under CERCLA.
States have traditionally acted  as  trustees  for groundwater, the
lands they own  (e.g., state parks and  forests), and  fish, game,
and other wildlife.  Trustees' responsibilities for  natural
resources are not always distinct and  can overlap.   As a result,
federal, state, and tribal trustees often act together to recover
natural resource damages.

     A damaged area can have more than one settlement when, for
example, there is more than one  responsible party.   Also, a
settlement can cover all or a portion  of an area's restoration.
Since a responsible party can be liable for damages  at more than
one area, some settlements cover more  than one area.*

     We performed our work at the Departments of Commerce,
Justice, and the Interior in Washington, D.C.  We also conducted
telephone interviews with officials from nine judgmentally
selected states, primarily in the office of each states'
attorneys general.  We conducted our review between  February and
May of 1995.

MOST SETTT^MKNTS WITH FEDERAL TRUSTEES
ARE VALUED AT LESS THAN 5200.OOP

     Most natural resource damage settlements with federal
trustees have required no payment or relatively small payments by
the responsible parties.  Five cases have accounted  for most of
the total value of the settlements.

     According to Department of  Justice data, in 48  of the 98
settlements reached through April 1995, federal trustees agreed
not to sue responsible parties for  injuries to natural resources
and required no payment unless new  and significant information
was later discovered.7   These agreements,  referred to  as
covenants not to sue, were granted  because federal trustees _
determined that either (1) the cleanup to be performed at a
Superfund site addressed their concerns about the natural
6While NOAA is the trustee for anadromous fish in freshwater and
coastal waters, Interior  is- responsible  for them only in
freshwater.

'Department of Justice officials said that 48 is the minimum
number of agreements that have been reached with no payments.
The Department has not kept a systematic  record of these
agreements.

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resources or  (2) no, natural  resources  under- federal trusteeship
were damaged  at  the site.  For  the  most  part,  federal  trustees
did not seek  to  recover damages  in  these cases.   Instead,  the
trustees agreed" to  these  settlements at  the  request of
responsible parties that  were seeking  early  and  complete
resolution of their environmental liability  at a Superfund site.

     The other 50 settlements involved monetary  recoveries for
natural resource damages  totaling an estimated $106 million.
(See app. II.)   with these recoveries, trustees  will take  actions
to restore damaged  resources, such  as  restocking fish, monitoring
the recovery  of  injured resources,  and creating  new wetlands or
other habitat.   In  some cases, these recoveries  may reimburse
trustees for  their  costs  of  assessing  resource injuries.

     Five' of  the 50 settlements  accounted for  $84.4 million  (80
percent) of the  $106 million recovered,  as of  April 1995.8  All
five settlements involved damages to coastal waters and/or
rivers.  These settlements are for  cleaning up contamination and
restoring biological resources  ('e.g.,  fish and lobster) in large
areas of coastal waters beyond the  area  where  a  Superfund  cleanup
was performed or where no'Superfund cleanup was  performed.9
Additional claims are pending or expected at two of these  areas —
Commencement Bay in Washington State and an offshore area  near
Los Angeles County  in California.   (See  app. Ill for more
information about these areas.)

STATES HAVE SETTLED SOME
DAMAGE CIAIMS INDEPENDENTLY

     According to officials  in the  office of their  state's,
attorney general, four states—Colorado,  Idaho,  New Jersey, and
New York—had settled 17  CSRCLA  claims that were- not filed
jointly with federal trustees for a total of, approximately $23.4
million.  These  17  settlements ranged  in value from about  $36,000
to $6.8 million.  'Seven claims-were settled for  about  $1 million
each.

     Natural resource damage practices varied  in these states.
For example, only one of  the nine states,  Wyoming,  had not
litigated any natural resource damage  claims.  On the other hand,
9In another case,  federal trustees settled for $15.1 million in
natural resource damages at the Summitville Mine Site in .
Colorado.  However, they did not recover any money because a
responsible party went bankrupt.

9These five areas  are Elliott Bay and Commencement Bay in
Washington State,  New Bedford Bay 'in Massachusetts, and an area
off-the shore of Los Angeles County and the Cantara Loop Train
Derailment in California.

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 New Jersey was more  active  and was the only state to use  its  own
 state  law exclusively to  litigate a natural resource damage case.

 THE NUMBER AND"VALUE OF FUTURE
 SETTLEMENTS ARE  UNKNOWN

     Federal officials could  not  predict  the number  or value  of
 future natural resource damage claims.  They were uncertain
 because the number and value  of such claims depend greatly on
 whether and to what  exten£.  future cleanup agreements  address
 injuries to natural  resources.  However,  Department  of Justice,
 NOAA, and state  officials were able to  identify  three instances
 where damage settlements could exceed $50 million.  Although
 these officials  thought other settlements could  exceed this
 amount, they were reluctant to make predictions  about specific
 geographic areas, except for  the  three  instances which all
 involve future or ongoing claims  of $500  million.

     One instance of  a pending high dollar value claim is an  area
 off the shore of Los  Angeles  County,  California.  According to
NOAA and Department  of Justice officials,  federal and state
 trustees will attempt to recover  about  $500 million to restore
damage caused by DDT  and polychlorinated  biphenyls (PCS)
contamination plus substantial  additional amounts to  compensate
 the public for the closing of  fisheries and other lost use of
 resources.  Trustees  have already settled one case for $12
million,  and a $42.2 million  settlement was recently  overturned
by a federal court of appeals.

     Two large mining areas were  also identified.  The Coeur
d'Alene River basin  in Idaho may  involve  between $600 million and
 $1 billion in damages, according  to Department of Justice
officials.  This area, extending  over several hundred square
miles,  encompasses more than  100 mines and includes the 21-
 sc^uare-mile Bunker Hill Superfund Site.   Mining  activities have
widely contaminated  the area's  soil, water,  and  air with lead and
other heavy metals.   In'addition,  emissions  from smelting
operations have destroyed large areas of  vegetation.   Federal
 trustees and the Coeur d'Alene  Tribe are  assessing the extent  of
damages in, this area.  The State  of Idaho has already recovered
 $4.5 million- in damages and is  not  part of  the ongoing
assessment.

     The upper Clark Fork River basin in  Montana encompasses .
nearly 127 miles of river corridor  and four  Superfund sites.   The
 state of Montana is seeking over  $600 million in damages  caused
by mining and smelting operations  conducted for  more than 100
years.   Hazardous substances are  still being released from the
 site,  and large quantities of  toxic metals  and acids—which
 continue to accumulate in the  river basin's  soil, sediment,  and
water—are still causing damage.  The federal government  has not
 filed a damage claim.

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 THE  FEDERAL  GOVERNMENT FACES
 POTENTIALLY  LARGE  DAMAGE  CLAIMS

      Our  discussions  with federal  officials  indicate that  it  is
.too  early to know  the potential  number  and value  of natural
 resource  damage  claims at federal  facilities.   The selection  of  a
 cleanup remedy at  many facilities  is  still years  away,  and until
 that  step is taken, the full  extent of  residual resource damages
 cannot be estimated.   However, Department  of Energy officials
 said  they expect large future damage  claims  in  part because the
 high  estimated cost of removing  contamination is  likely to
preclude  complete  remediation at many of their  facilities.  They
 recognize that residual resource losses are  larger when only part
 of the contamination  is removed.

      The  federal government already has significant liability for
cleaning  up  hazardous waste sites  oh  its facilities.  The  cleanup
bill  for  the Department of Energy  alone is expected to  be  about
$300  billion. Other federal agencies  have  hazardous waste  sites
that  will  need to  be  cleaned  up  as well.   For example,  the
Department of Defense has thousands of hazardous  waste  sites on
its installations  and the Department  of the  Interior has
thousands  of  abandoned and inactive mine sites  on lands that it
administers.

      In fact, Colorado, one of the states  we contacted, has a
damage claim pending  at the Department of  Defense's Rocky
Mountain Arsenal.  This claim was  filed before  1986, when  CERCLA
was amended  to restrict claims from being  filed before cleanup
remedies were selected.  States  and Indian tribes  are expected to
file  other damage  claims at federal facilities  in  the future,
according  to officials  in the Departments  of Defense and Energy.

0 B S ERVATIONS

      To date, natural  resource damage settlements have been
relatively low—accounting for a small percentage of what
responsible parties have agreed  to pay for Superfund cleanups.
However,  federal and  state officials  told  us of three future
settlements  that could involve hundreds of millions of dollars.
They  also indicated that there may be other future  instances
where claims will  exceed $50 million per geographic area.
Further, the  federal  government  faces the potential  for large
damages at some  of its  most contaminated facilities.

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APPENDIX I
                       APPENDIX I
      Number and Value of Natural
      Resource Damage Cases
        Number
  48 Cases Settled
  With No Payment
  Required
 9 Cases
$500K-$5M
   5 Cases
  S12M-S25M
        36 Cases Up to $499K
                   Value
                          $21.6M
                          Recovered From
                          Remaining Cases
                                   $84.4M Recovered From
                                     Rve Largest Cases
Note:  There were no.cases between $5 million and $12 million.

Source:  GAO's analysis of data from the Department of Justice.

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APPENDIX  I!
         FEDERAL JJATTTPAT, RESOURCE  DAMAGE CASES UNDER
                  (Settlements as of  April 26,  1995)
                                                           APPENDIX i:
Case Name1
1 . City of Seattle
2. AVX Corp.
3. Southern Pacific Transportation Co.
4. Simpson Tacoma Kraft CoVPort of i /
Tacoma "
5. Montrose Chemical Corp.
6. Eagle-Picher Industries (In re) *
7. Sharon Steel Corp. _/
8. Schlumberger Industries
9. New York Trap Rock Corp.
10. Charles George Trucking Co.
11. The Carborundum Co.
12. Chateaugay Corp. (In re)
13. BP America, Inc.
1 4. New Port Largo
15. Midwest Solvent Recovery
16. U.E. Systems, Inc. (In re)
17. National Gypsum Co. (In re)
18. Thatcher Company
19. Bliss
20. Blackbird Mining Ltd. Partnership/ _/
M.A. Hanna Mining Co.3
21. Accurate Partitions Corp.
22. Insilico Bankruptcy (In re)
23. Santa Clara I
24. Bayard Mining Co. ^/
25. Lonestar Industries, Inc.
Site name, state
Elliott Bay, WA
New Bedford, MA (Acushnet River/New Bedford Harbor)
Cantara Loop Train Derailment, CA
Commencement Bay, WA
Montrose Superfund Site, CA
Tri-State Mining District Superfund Site: MO, KS, OK
Midvak* Tailing Superfund Site, UT
Crab Orchard National Wildlife Refuge, IL
Portland Cement Superfund Site, UT
Charles George Reclamation Trust Landfill, MA
Cafcfwell Trucking Co. Superfund Site, N J
Six Superfund Sites: Arrowhead Refining, MN
Cherokee Co., KS, G&H Landfill, Ml, 9th Ave.
Dump, IN, Tar Creek, OK & Royal Hardage, OK
Army Creek Landfill Superfund Site, DE
New Port Largo Superfund Site, FL
Midco Sites I and II, IN
Three Superfund Sites, IN: Midco Sites I & II,
9th Avenue Dump, and Douglas Road Landfill
Seven Superfund Sites: NJ, PA, FL, NH, IL
John Day Acid Spill, OR
Missouri Dioxin Superfund Site, MO
Blackbird Mine Site, ID
Fisher-Calo Superfund Site, IN
Midco Sites I & II (9th Avenue Dump & Oak Grove), IN
Kyriakoputos International Superfund Site, SO
Cleveland Mill Site. NM
Portland Cement Site, UT
$Value2
$24,250,000
21,127,371
14,000,000
13,035,000
12,000,000
4,734,000
2,600,000
2,500,000
2,207,510
1,378,350
1,024,434
941,000
800,000
550,000
423,961
373,000
361,353
275,000
250,000
250,000
220,000
214,840
205,000
200.000
200.000

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APPENDIX II
                                                         APPENDIX II
         FEDERAL NATURAL RESOURCE DAMAGE CASES UNDER CERCLA
               -  (Settlements as of April 26, 1995)
Case1
26. Energy Cooperative, Inc. (In re)
27. AMF Reece, Inc.
28. Oak Grove Sanitary Landfill Trust
29. French Ltd., Inc.
30. Jack's Creek/Sitkin Superfund Site
31. Arrowhead Refining Co.
32. Phoenix Capital Enterprises
33. Shore Realty
34. Great Lakes Asphalt
35. GATX Corp.
36. Kowinsky Farms, Inc.
37. A.F. Murphy /Solvents Recovery
Service of New England
38. Active Products
39. American Waste Processing
40. I. Jones Partnership
41. Uniroyal, Inc. (In re)
42. Cuyahoga Equip. Co. (In re)
43. Southern Lakes Trap & Skeet Club
44. Farber
45. Core Craft, Inc.
46. Anderson, Greenwood, & Co.
47. LJnemaster Switch Corp.
48. AVX Corp.
49. Manville Corporation
50. Summttville Consolidated Mining Co.,/
(In re)4 •
TOTAL
MEDIAN
Site name, state
ECl Refinery Facility Site, IN
PSC Resources Superfund Site, MA
Oak Grove Sanitary Landfill Site, MN
French Limited Superfund Site, TX
Jack's Creek/Sitkin Smelting Superfund Site, PA
Arrowhead Refining Co. Superfund Site, MN
Vertac Superfund Site, AR
Appfied Environmental Services Site, NY
Zionsville Superfund Site, IN
Saegertown Superfund Site, PA
Cokers Landfill Superfund Site, OE
Solvent Recovery Service Site, CT
Wayne Reclamation Superfund Site, IN
Northside Sanitary Landfill, IN
Clinton Street Superfund Site, IL
Three Superfund Sites, IN: Midco Sites 1 & II,
9th Avenue Dump, and Douglas Road Landfill
Pubicker Industries Superfund Site, NY
Southern Lakes Trap & Skeet Club Site, Wl
Syncon Resins Superfund Site, NJ
Kummer Sanitary Landfill, MN
Sheridan Disposal Superfund Site, TX
LJnemaster Switch Corp. Superfund Site, CN
Sullivan's Ledge Superfund Site, MA
Johns-Manville Superfund Site, NY
Summitville Mine Site, CO


SValue2
200,0(30
153,720
148,600
140.580
136,465
134,800
129,000
124,000
123,670
' 94,510
80,000
76,935
74,999
55,000
55,000
49,710
40,000
31,912
25,000
22,000
20,000
6,000
5,000
3,779
0
$106,051,499
S200.000
                               10

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        APPENDIX  II                                                              APPENDIX  II

                    FEDERAL NATURAL  RESOURCE DAMAGE  CASES  UNDER  rraCLA
                                (Settlements  as  of  April 26,  1995)

'Depiction of cases is based on data-from the Department of Justice, whose classifications sometimes group more than
one settlement per case. The name of the case may not correspond to the name of the parties paying the damages.  All
cases have been brought by the U.S. government except the cases marked by (In re);  this term denotes a bankruptcy
case involving more parties than the U.S. government.

2The data reflect the estimated doHar value of the case as of April 26, 1995, and may change where cleanup actions,
assessments, or bankruptcy proceedings are to be completed. For example, in U.S. vs. plackblrd Mining Ltd. Partnership.
the $250,000 reported is for only one smaH responsible party and the natural resource damage is collected out of any
moneys (up to $250,000) left over after the cleanup is completed.
     reflects a settlement with only one of the small responsible parties at the Blackbird Mina Site, litigations are
currently ongoing against other parties.

'Court allowed $15.1 million for damages to natural resources, but no money was recovered because the company went
bankrupt.

Source:  Department of Justice,
                                                   11

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 APPENDIX  III   '   .                                     APPENDIX III


                   THE FIVE AREAS WITH THE LARGEST
                      FEDERAL DAMAGE SETTLEMENTS

     The  following briefly describes  the  five  largest  damage
 settlements involving federal  trustees, as  of  April  26, 1995.

 ELLIOTT BAY/SEATTLE,  WASHINGTON

     Elliott Bay  is a 21-square-kilometer area in  central Puget
 Sound encompassing the commercial waterfront district  of Seattle.
 Over the past 150  years, the Elliott  Bay/Duwamish  River estuary has
 been contaminated  by  many  hazardous substances, including chromium,
 cadmium, copper,  lead, zinc, and several toxic and/or  carcinogenic
 organics, such as  polychlorinated biphenyls  (PCB)-1  These
pollutants have extensively contaminated nearshore sediments,
 reducing the value of  the  area as a habitat for fish and wildlife.
 In 1991, the federal,  state and  tribal trustees for  Elliott Bay
reached a $24 million legal settlement with the city of Seattle and
the municipality of metropolitan Seattle.  The settlement allocated
 $12 million for sediment remediation, $10. million  for  habitat
development, and $2 million for  pollution source control.

NEW BEDFORD HARBOR, MASSACHUSETTS

     The New Bedford Harbor case was  one of the first  natural
resource damage cases  filed under the Comprehensive  Environmental
Response, Compensation, and Liability Act (CERCLA).  Located near
Buzzards Bay,  Massachusetts, the harbor has long been  used by the
 fishing, shipping, and manufacturing  industries.   After studies
during the 1970s found high levels of PCBs and heavy metals in the
harbor's fish and  shellfish, several  fishing areas were closed.
Federal and state  trustees  reached a  $21.1 million settlement with
 five companies to  cover the costs of  assessment and  restoration.
The companies also agreed  to an  $88 million Superfund  cleanup
 settlement with EPA and the state.  The value  of restoration work
 is contingent upon the scope of  the cleanup remedy that EPA selects
 for the outer harbor.  Restoration projects under consideration by
 the trustee* include  the improvement,  of anadromous fish runs,  the
re-establishment of seagrass beds, the creation of wetlands,  and
 the construction of artificial reefs.  The trustees  are currently
developing a restoration plan that will outline the  criteria for
xPCBs,  when released in the environment,  decompose very slowly and
can accumulate in plants, animals, and human tissue.  Laboratory
test show that they cause cancer in rats and mice and have adverse
effects on fish and wildlife.  PCBs, which  are used primarily in
electrical equipment, are generally banned from use in the United
States.
                                 12

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APPENDIX  III.            .                     -   -       APPENDIX  III


selecting the  restoration  projects.

CANTARA LOOPTRAIN DERAILMENT.  CALIFORNIA

      In July 1991,  a train derailed  on a stretch of  track  known as
the "Cantara loop"  near Dunsmir,  California,  The  derailment
spilled approximately 19,000 gallons of the herbicide metam sodium,
into  the  upper Sacramento  River.   The spill destroyed all  aquatic
life  along a 42-mile stretch of the  river and caused extensive
injuries  to a  native trout fishery as well as to the river's
ecosystem.  This  case was  settled in March 1994, for $14 million.
The federal and state trustees  have  already taken  some  emergency
restoration actions,  such  as re-establishing  the native rainbow
trout population,  and are  planning other restoration projects.

COMMENCEMENT BAY/TACOMA. WASHINGTON

      Commencement Bay is an estuarine bay located  in the southern
part  of Puget  Sound.   Industrialization and urban  development have
severely  degraded natural  habitats in the bay by introducing a
variety- of hazardous substances- into the surface and- groundwater
and the sediments of the bay area.   Much of the  bay's nearshore
•area  is a National  Priority List-Super fund site.   Federal,  state
and tribal,' trustees negotiated  a  settlement with the Port  of Tacoma
and the Simpson Tacoma Kraft Company for about $13 million.  Moneys
from  the  settlement will be used  to  restore,  replace, or acquire
the equivalent components  of the  historical ecosystem,  including
vegetated shallows,  mudflats, tidal  marshes and  creeks, off-channel
sloughs and lagoons,  naturalized  stream channels,  and adjacent
upland buffer  areas.   Most site-specific restoration projects will
not be selected until after early 1996.

OFFSHORE  LOS ANGELES COUNTY.  CALIFORNIA

      Approximately  2,000 metric tons of  DDT and  PCBs were
discharged into the southern California marine environment  through
the local county  sewer system.  The  state of  California issued  a
health advisory against the consumption of fish  from the area
because of dangerous concentrations  of DDT and PCBs  and a
commercial fishery was closed.  In June 1990, the  Department of
Justice filed-a claim on behalf of. NOAA and the  Department  of the
Interior  against  the 10 responsible  parties for  injury  to natural
resources  caused  by discharges  of DDT and PCBs into  the marine
environment.   Federal and  state trustees settled one case  for $12
million.   In March  1995, a federal court of appeals  overturned  a
second $42.2 million settlement with the Los  Angeles County
sanitation district and municipalities and sent  the  settlement  back
to the federal district court for reconsideration.
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